Bill C-43 (Historical)

Economic Action Plan 2014 Act, No. 2

A second Act to implement certain provisions of the budget tabled in Parliament on February 11, 2014 and other measures

Part 1 implements certain income tax measures proposed in the February 11, 2014 budget. Most notably, it
(a) extends the intergenerational rollover and the lifetime capital gains exemption for dispositions of property used in farming and fishing businesses;
(b) extends the tax deferral provision with respect to breeding animals to bees, and to all types of horses that are over 12 months of age, that are kept for breeding;
(c) permits income contributed to an amateur athlete trust to qualify as earned income for RRSP contribution limit purposes, with an election available to taxpayers for up to a three-year retroactive application;
(d) extends the definition “split income” to include income from a business or property that is paid or allocated to a minor child from a partnership or trust where a person related to the child is engaged in the activities of the partnership or trust to earn that income;
(e) eliminates graduated rate taxation for trusts and certain estates with an exception for cases involving testamentary trusts whose beneficiaries include individuals eligible for the Disability Tax Credit;
(f) eliminates the 60-month exemption from the non-resident trust rules;
(g) allows an individual’s estate to carry back charitable donations made as a result of the individual’s death;
(h) expands eligibility for the accelerated capital cost allowance for clean energy generation and energy conservation equipment to include water-current energy equipment and a broader range of equipment used to gasify eligible waste fuel;
(i) adjusts Canada’s foreign accrual property income rules in order to address offshore insurance swap transactions and ensure that income from the direct or indirect insurance of Canadian risks is taxed appropriately;
(j) better circumscribes the existing “investment business” definition in the foreign accrual property income regime;
(k) addresses back-to-back loan arrangements involving an intermediary; and
(l) extends the existing tax credit for interest paid on student loans to interest paid on a Canada Apprentice Loan.
Part 1 also implements other selected income tax measures. Most notably, it
(a) alleviates the tax cost to Canadian-based banks of using excess liquidity of their foreign affiliates in their Canadian operations;
(b) ensures that certain securities transactions undertaken in the course of a bank’s business of facilitating trades for arm’s length customers are not inappropriately caught by the base erosion rules;
(c) modernizes the life insurance policy exemption test;
(d) amends the foreign affiliate rules to ensure they apply appropriately to structures that include partnerships and makes generally relieving changes to certain of the base erosion rules to ensure they do not apply in unintended circumstances;
(e) amends the rules for determining the residence of international shipping corporations;
(f) provides for the appropriate taxation of taxpayers that invest in Australian trusts;
(g) amends the foreign affiliate dumping rules to ensure the rules apply in appropriate circumstances and, if applicable, provide appropriate results;
(h) excludes from the definition “non-qualifying country” in the foreign affiliate rules those countries or other jurisdictions for which the Convention on Mutual Administrative Assistance in Tax Matters is in force and effect;
(i) avoids unintended tax consequences with respect to the British Overseas Territory of the British Virgin Islands;
(j) simplifies the rules for the Canadian Film or Video Production Tax Credit regime;
(k) amends the trust loss restriction event rules to provide relief for investment trusts that meet specific conditions; and
(l) increases the maximum amount that may be claimed under the Children Fitness Tax Credit and makes the credit refundable starting in 2015.
Part 2 implements certain goods and services tax/harmonized sales tax (GST/HST) measures by
(a) ensuring that pooled registered pension plans are subject to similar GST/HST treatment as registered pension plans;
(b) implementing real property technical amendments that provide for the consistent treatment of different types of housing and ensure that the special valuation rule for subsidized housing works properly with the GST/HST place of supply rules and in the context of a GST/HST rate change;
(c) clarifying the application of GST/HST public service body rebates in relation to non-profit organizations that operate certain health care facilities; and
(d) relieving the GST/HST on services of refining precious metals supplied to a non-resident person that is not registered for GST/HST purposes.
Part 3 amends the Excise Act, 2001 to provide a refund of the inventory tax, introduced in the February 11, 2014 budget, on cigarettes that are destroyed or re-worked, in line with the refund of the excise duty that exists for tobacco products that are destroyed or re-worked.
Part 4 enacts and amends several Acts in order to implement various measures.
Division 1 of Part 4 amends the Industrial Design Act to make that Act consistent with the Geneva (1999) Act of the Hague Agreement Concerning the International Registration of Industrial Designs and to give the Governor in Council the authority to make regulations for carrying it into effect. The amendments include provisions relating to the contents of an application for the registration of a design, requests for priority, and the term of an exclusive right for a design.
It also amends the Patent Act to, among other things, make that Act consistent with the provisions of the Patent Law Treaty. The amendments include reducing the requirements for obtaining a filing date in relation to an application for a patent, requiring that an applicant be notified of a missed due date before an application is deemed to be abandoned, and providing that a patent may not be invalidated for non-compliance with certain requirements relating to the application on the basis of which the patent was granted.
Division 2 of Part 4 amends the Aeronautics Act to authorize the Minister of Transport to make an order, and the Governor in Council to make regulations, that prohibit the development or expansion of or any change to the operation of an aerodrome. It also amends the Act to authorize the Governor in Council to make regulations in respect of consultations by the proponents and operators of aerodromes.
Division 3 of Part 4 enacts the Canadian High Arctic Research Station Act, which establishes a new federal research organization that is to be responsible for advancing knowledge of the Canadian Arctic through scientific investigation and technology, promoting the development and dissemination of knowledge of the other circumpolar regions, strengthening Canada’s leadership on Arctic issues and ensuring a research presence in the Canadian Arctic. It also repeals the Canadian Polar Commission Act and makes consequential amendments to other Acts.
Division 4 of Part 4 amends section 207 of the Criminal Code to permit charitable or religious organizations to carry out, with the use of a computer, certain operations relating to a provincially-licensed lottery scheme.
Division 5 of Part 4 amends the Federal-Provincial Fiscal Arrangements Act to adjust the national standard for eligibility for social assistance to provide that no minimum period of residence is to be required for Canadian citizens, for permanent residents, for victims of human trafficking who hold a temporary resident permit or for protected persons.
Division 6 of Part 4 amends the Radiocommunication Act to:
(a) introduce an administrative monetary penalty regime;
(b) explicitly prohibit jammers, subject to exemptions provided by the Minister of Industry;
(c) provide for the enforcement of rules, standards and procedures established for competitive bidding systems for radio authorizations;
(d) modernize wording relating to the powers of inspectors and the requirements to obtain warrants;
(e) authorize inspectors to request information in writing and to seize non-compliant devices; and
(f) authorize the Minister of Industry to share information with domestic and foreign bodies for the purpose of regulating radiocommunication.
Division 7 of Part 4 amends the Revolving Funds Act to correct an error in the heading before section 4 by replacing the reference to the Minister of Foreign Affairs with a reference to the Minister of Citizenship and Immigration. The amendment is deemed to have come into force on July 2, 2013.
Division 8 of Part 4 amends the Royal Canadian Mint Act to eliminate the anticipation of profit by the Royal Canadian Mint with respect to the provision of goods and services to the Government of Canada.
Division 9 of Part 4 amends the Investment Canada Act to require foreign investors to provide notification whenever they acquire a Canadian business through the realization of security on a loan or other financial assistance, unless another Act applies. It also allows public disclosure of certain information related to the national security review process and makes related amendments to another Act.
Division 10 of Part 4 amends the Broadcasting Act to prohibit a person who carries on a broadcasting undertaking from charging a subscriber for providing the subscriber with a paper bill.
Division 11 of Part 4 amends the Telecommunications Act to provide the Canadian Radio-television and Telecommunications Commission (CRTC) with the authority to impose certain conditions concerning the offering and provision of services on providers of telecommunications services that are not telecommunications carriers, to prohibit providers of telecommunications services from charging subscribers for the provision of paper bills, to allow for sharing of information between the CRTC and the Competition Bureau, to provide the CRTC with the authority to impose administrative monetary penalties for violations of the Telecommunications Act, CRTC decisions and regulations, to provide the Minister of Industry with the authority to establish a registration system and update other processes relating to telecommunications apparatus in order to assess conformity with technical requirements, and to update inspection powers for ensuring compliance with that Act.
Division 12 of Part 4 amends the Business Development Bank of Canada Act to clarify the financial and management services that the Business Development Bank of Canada is authorized to provide, including financial services in respect of enterprises operating outside Canada. It also makes some changes to the governance provisions of that Act.
Division 13 of Part 4 amends the Northwest Territories Act — enacted by section 2 of chapter 2 of the Statutes of Canada, 2014 — to provide that, if the election period for the first general election under that Act would overlap with the election period for a federal general election, then the maximum duration of the first Legislative Assembly of the Northwest Territories under that Act may be extended until five years from the date fixed for the return of the writs at the last general election under the former Northwest Territories Act (chapter N-27 of the Revised Statutes of Canada).
Division 14 of Part 4 amends the Employment Insurance Act to allow for the refund of a portion of employer premiums paid by small businesses in 2015 and 2016. An employer is eligible for that refund if its premium is $15,000 or less for the year in question.
It also amends that Act to exclude from reconsideration under section 112 of that Act decisions of the Canada Employment Insurance Commission made under the Employment Insurance Regulations respecting the writing off of penalties owing, amounts payable or interest accrued on any penalties owing or amounts payable.
Division 15 of Part 4 amends the Canada-Chile Free Trade Agreement Implementation Act in order to implement amendments to the dispute resolution mechanism of the Canada-Chile Free Trade Agreement.
Division 16 of Part 4 amends the Canada Marine Act to provide for the power to make regulations with respect to undertakings that are situated in a port. It also authorizes those regulations to incorporate by reference documents, including the laws of a province. Finally, it authorizes port authorities to acquire federal real property or federal immovables and to lease or license any real property or immovable other than federal real property or federal immovables.
Division 17 of Part 4 amends the DNA Identification Act to, among other things,
(a) create new indices in the national DNA data bank that will contain DNA profiles from missing persons, from their relatives and from human remains to assist law enforcement agencies, as well as coroners, medical examiners and persons or organizations with similar duties or functions, to find missing persons and identify human remains;
(b) create a new index that will contain DNA profiles from victims of designated offences to assist law enforcement agencies in identifying persons alleged to have committed designated offences;
(c) create a new index that will contain DNA profiles derived from bodily substances that are voluntarily submitted by individuals to assist in either the investigations of missing persons or designated offences;
(d) establish criteria for adding and retaining DNA profiles in, and removing them from, the new indices, and transferring profiles between indices;
(e) specify which DNA profiles in the existing and new indices will be compared with each other;
(f) specify the purposes for which the Commissioner of the RCMP may communicate the results of comparisons of DNA profiles and the purposes for which that information may be subsequently communicated; and
(g) specify the uses to which the results of comparisons of DNA profiles may be put.
It also makes consequential amendments to the Access to Information Act and the Public Servants Disclosure Protection Act.
Division 18 of Part 4 amends the Proceeds of Crime (Money Laundering) and Terrorist Financing Act to provide that certain foreign entities that are engaged in the money-services business are included in the definition “foreign entity”.
Division 19 of Part 4 amends the Department of Employment and Social Development Act to eliminate the limit on the number of full-time and part-time members of the Social Security Tribunal.
Division 20 of Part 4 amends the Public Health Agency of Canada Act to create a new position of President as deputy head of the Public Health Agency of Canada, thereby separating the responsibilities of the Chief Public Health Officer from those of the deputy head of the Agency.
Division 21 of Part 4 amends the Economic Action Plan 2013 Act, No. 2 in order to provide that certain provisions of Division 8 of Part 3 of that Act apply to any corporation resulting from an amalgamation referred to in that Division, and to provide that certain provisions of the Blue Water Bridge Authority Act continue to apply to the Blue Water Bridge Authority after its continuance.
Division 22 of Part 4 amends several Acts to discontinue supervision of provincial central cooperative credit societies by the Office of the Superintendent of Financial Institutions, to eliminate tools for federal intervention in relation to those centrals and to provincial local cooperative credit societies, and to facilitate the entry of provincial cooperative credit societies into the federal credit union system by simplifying the process for continuation and amalgamation that applies to them.
Division 23 of Part 4 amends the Financial Administration Act to authorize Her Majesty in right of Canada to neither pay nor collect low-value amounts, except amounts owed by Crown corporations to persons other than Her Majesty in right of Canada, amounts payable to Crown corporations by such persons, amounts payable under the Air Travellers Security Charge Act, the Excise Act, 2001, the Excise Tax Act, the Income Tax Act or the Softwood Lumber Products Export Charge Act, 2006, and amounts related to the public debt or to interest on the public debt. It also provides Treasury Board with the authority to make regulations to set a low-value threshold, to specify circumstances for the accumulation of amounts and to exclude amounts, as well as regulations generally respecting the operation of the authority to neither pay nor collect low-value amounts.
Division 24 of Part 4 amends the Immigration and Refugee Protection Act to, among other things,
(a) replace references to an opinion provided by the Department of Employment and Social Development, with respect to an application for a work permit, with references to an “assessment”;
(b) authorize the Minister of Citizenship and Immigration or the Minister of Employment and Social Development to publish on a list the name and address of an employer who, among other things, has been convicted of certain offences; and
(c) authorize the Governor in Council to make regulations
(i) regarding the publication and removal of the names and addresses of employers,
(ii) regarding the power to require documents from any individual or entity for inspection in order to verify compliance with regulatory conditions,
(iii) requiring an employer to provide prescribed information in relation to a foreign national’s authorization to work in Canada for the employer,
(iv) governing fees to be paid for rights and privileges in relation to an assessment provided by the Department of Employment and Social Development with respect to an application for a work permit,
(v) governing fees to be paid in respect of the compliance regime that applies to employers in relation to their employment of certain foreign nationals,
(vi) regarding the collection, retention, use, disclosure and disposal of Social Insurance Numbers, and
(vii) regarding the disclosure of information for the purposes of cooperation between the Government of Canada and the government of a province.
Division 25 of Part 4 amends the Judges Act and the Federal Courts Act to implement the Government’s Response to the Report of the Special Advisor on Federal Court Prothonotaries’ Compensation with respect to the salary and benefits of the prothonotaries of the Federal Court.
Division 26 of Part 4 amends the Canadian Payments Act to make changes to the governance structure of the Canadian Payments Association and to add new obligations in respect of accountability, including by
(a) changing the composition of the Board of the Directors of the Association and the procedures for selecting the directors of the Board;
(b) establishing a Member Advisory Council;
(c) expanding the power of the Minister of Finance to issue directives to the Association; and
(d) adding new obligations in respect of the preparation of annual reports and corporate plans.
Division 27 of Part 4 amends the Payment Clearing and Settlement Act to expand and enhance the oversight powers of the Bank of Canada with respect to systems for the clearing and settlement of payment obligations and other financial transactions, so that the Bank is better able to identify risks related to financial market infrastructure and to respond in a timely and proactive manner. It also makes minor consequential amendments to other Acts.
Division 28 of Part 4 enacts the Extractive Sector Transparency Measures Act in order to impose the following obligations on entities that are engaged in the commercial development of oil, gas or minerals for the purpose of implementing Canada’s international commitments in the fight against corruption:
(a) the obligation to report to the responsible Minister certain payments made to payees; and
(b) the obligation to make reported information accessible to the public.
For the purpose of verifying compliance, the Act provides for an inspection regime and gives a power to the responsible Minister to require an entity to provide certain information. Finally, the Act provides for certain offences relating to the obligations under the Act.
Division 29 of Part 4 amends the Jobs and Economic Growth Act to provide that Canadian Nuclear Laboratories Ltd. (CNL) is an agent of Her Majesty in right of Canada, effective as of the date of CNL’s incorporation, and to provide that CNL will cease to be an agent on the day on which Atomic Energy of Canada Limited disposes of CNL’s shares. The Division also amends that Act to provide that the Public Service Superannuation Act will apply for a transitional period of three years to persons who are employees of CNL on that day.
Division 30 of Part 4 repeals a provision of the Economic Action Plan 2013 Act, No. 2 that amended a provision of the Public Service Labour Relations Act. It also amends provisions of the Economic Action Plan 2013 Act, No. 2 that amended the Public Service Employment Act in respect of the staffing complaint process.
It also makes a technical correction to a coordinating amendment in the Economic Action Plan 2013 Act, No. 2.
Division 31 of Part 4 transfers the pensionable service that is to the credit of certain Royal Canadian Mounted Police pension contributors under the Royal Canadian Mounted Police Superannuation Act to the Public Service Superannuation Act and deems those contributors to be Group 1 contributors under the Public Service Superannuation Act. It also amends the Royal Canadian Mounted Police Superannuation Act to repeal provisions relating to members of the Royal Canadian Mounted Police not holding a rank.

Motions in amendment

[Elizabeth May, Green, Saanich—Gulf Islands, BC]

Mr. Speaker, I am not the least bit reassured by the fact that the newly appointed Chief Public Health Officer thinks that things will be fine. He is an expert in public health and he is a fine medical doctor, but I do not think that he fully appreciates the distinctions and the importance of independence. The fact is that the chief public health officer for the Province of British Columbia, speaking on behalf of all public health officers at the provincial level across Canada, protests this change and believes that it is a big mistake.

I would refer to a letter from Dr. Trevor Hancock, a professor and senior scholar at the School of Public Health and Social Policy at the University of Victoria, whom I know well. Dr. Hancock has warned that this is violating “...the importance of a medical officer of health being an independent officer was established in the 19th century and is as true today as it was then, given the adverse health effects of poverty and of our industrial economy....”

Clearly, the role should be independent. It is important for the public health officer to have the status of deputy minister so that with the other deputy ministers within the Government of Canada, information is shared quickly and directly, and that relationships are built between the Chief Public Health Officer and the other deputies.

This is an enormous mistake. I fear that the current public health officer will come to agree with me.

[Earl Dreeshen, Conservative, Red Deer, AB]

Mr. Speaker, today I wish to speak to Bill C-43 and about families.

The week after the events of October 22, my wife Judy and my daughter Megan and our then 10-month-old grandson came to Ottawa to be with Dad. Like many of us, I underestimated the effect that day had on our friends and our loved ones. Touring this building together, watching my grandson sit where you are sitting, Mr. Speaker, brought home how important our families really are.

Our new family friendly tax measures would make it easier for all kids to get involved in the many exciting opportunities that exist in their communities. For that, as community representatives, we should all be proud. This is the reason that economic action plan 2014 has my backing. It is a tremendous support for Canadian families. This bill would put more money back into the pockets of Canadian families, and work on improving the fairness and integrity of our tax system by closing loopholes and strengthening tax enforcement to ensure that all Canadians, not just a select few, have lower and fairer taxes. Under this plan, every family with children would have money put back into their pockets so they can spend their money on their priorities.

These latest tax cuts and benefits would see an average Canadian family save close to $1,140 in 2015. All in all, these savings represent close to $27 billion returned to the pockets of Canadian families over the next five years. These latest tax cuts and benefits include the introduction of a family tax cut, an increase and expansion of the universal childcare benefit, an increase in the childcare expense deduction limits, and a doubling of the children's fitness tax credit, as well as making it refundable.

The new family tax cut is a federal tax credit that would allow a higher-income spouse to transfer up to $50,000 of taxable income to a spouse in a lower tax bracket. This credit would provide tax—

I remember when my kids were young and we took them to everything. People would say that I must put in thousands of miles just driving my own and neighbouring kids to sports and community events. At the time, it never really dawned on me. After all, there was the excitement of watching my son Devin score the first touchdown for our new football team on the same field where my youngest brother had scored the last touchdown 20 years earlier before that team had folded; or the excitement of watching our daughter, after being fouled at the buzzer during the very first game for the Elnora junior high basketball team, then sink both foul shots to first tie and then win the game. I have seen NBA players who cannot do that. The coaching, watching my kids and their teammates competing at regional and provincial levels in all types of sports, performing in plays and pageants, and even working on the farm together are memories of a family that worked, played, and laughed together. What about all those miles? I have always said I would much sooner drive my kids around than drive around looking for my kids.

[The Deputy Speaker, Joe Comartin]

Order, please. The hon. member for Skeena—Bulkley Valley is rising on a point of order.

[Nathan Cullen, NDP, Skeena—Bulkley Valley, BC]

Mr. Speaker, I apologize for interrupting my friend.

I was listening to his speech and the measures he was talking about, and I was looking for some reference point back to the bill that we are debating. The measures that he is—

[An hon. member]

Oh, oh!

[Nathan Cullen, NDP, Skeena—Bulkley Valley, BC]

Mr. Speaker, my friends can argue if they would like, but the measures he is referring to are not in this bill and are not relevant to this bill. This is the budget implementation act. The member is discussing measures that have not yet been introduced and are certainly not introduced through this legislation. It is just a question of relevance.

[The Deputy Speaker, Joe Comartin]

I am at a disadvantage of not knowing that bill well enough to know whether in fact the contents of this speech are relevant. I would like some comment from the member for Red Deer.

[Earl Dreeshen, Conservative, Red Deer, AB]

Mr. Speaker, to the point of order, certainly the discussion on tax reform refers to what is in the bill. If that speaks to the relevance of it, I would be happy to continue.

[Nathan Cullen, NDP, Skeena—Bulkley Valley, BC]

Mr. Speaker, I very much appreciate it is a 468 page bill. I do not know if you have gone through every page yet. I am not sure my friend has, or others in the House, but it is an incredibly complicated bill.

He is speaking very specifically about a number of measures that are not contained in the bill. It is one thing to say that he is speaking about taxes. It may change in the rest of the discourse. He may have a speech that is about the measures contained in the bill. We welcome that debate. We are here to debate the amendments that we brought forward and also the bill itself, if that is the broad interpretation of what this debate is about.

I know he is getting some sage advice, but to get into other measures that are completely not contained in the legislation stretches the bounds of relevance. Again, I understand the disadvantage he has of whether it is in Bill C-43. It is one of those moments where I say “Trust me on this one.” The measures he has discussed so far are not at all contained in the bill. They are not referenced. There is no enabling amendments or pieces of legislation. It is just not contained in the bill.

If he wants to speak to Bill C-43 or the amendments we have moved, then of course we are interested in the debate. He now is getting papers from the lobby, which I am sure will help move this discourse along.

[Elizabeth May, Green, Saanich—Gulf Islands, BC]

Mr. Speaker, I apologize for taking the floor. I have read the bill carefully and I have to agree with my friend from Skeena—Bulkley Valley. However, it is in the tradition of this place to both force down omnibus budget bill measures and to debate things that are not in them. On Bill C-38, we often heard from ministers of the crown about sections of the bill that did not in fact exist.

[Earl Dreeshen, Conservative, Red Deer, AB]

Mr. Speaker, it is called the children's fitness tax credit and it is in the bill.

The hon. member had spoken of perhaps discussing some of the salient points that they had in their motions, such as amending by deleting the long title, amending by deleting the short title and amending by getting rid of this clause. Further deep thought involved with the motions were delete, delete and delete.

From that position, they go to the Green Party with more deep thought to delete, delete and delete. This is the type of thing we are seeing. Therefore, if they want to speak to their motions, we could go that route.

[The Deputy Speaker, Joe Comartin]

I am going to end the point of order. The member for Red Deer has made the point that at least the income tax credit is in the bill. That at least ties it well enough to relevancy that I think the point of order is not well taken.

I will allow the member for Red Deer to continue, again cautioning him that all members of the Speaker's office have made it clear over the past few weeks that we will look more closely at relevancy. Therefore, I would ask him to, as much as possible, keep his comments relevant to Bill C-43.

[Elizabeth May, Green, Saanich—Gulf Islands, BC]

Mr. Speaker, I rise on a separate point of order. In the course of defending the hon. member for Red Deer, in the course of rebutting the member for Skeena—Bulkley Valley's point of order, he made a gratuitous comment that the Green Party amendments were all deletions.

I would draw to his attention that in my speech I complained of the fact that the Conservative Party members had deprived me of the right I have under the rules of this place to bring forward substantive amendments. I would much rather be able to do what is my right, to bring forward substantive amendments at report stage, but the actions of his majority party have made that impossible.

[The Deputy Speaker, Joe Comartin]

That is not a point of order. It is a matter of debate.

The hon. member for Red Deer has four minutes left in his speech.

[Earl Dreeshen, Conservative, Red Deer, AB]

Mr. Speaker, I was talking about families. Perhaps it is an opportunity, if people have listened, to talk about how difficult it is sometimes to bring up issues that are important to families. I am somewhat perplexed by some of the things that have been mentioned by the opposition.

I know that Jack Mintz, one of Canada's leading economists and the current director of the Palmer Chair in Public Policy at the University of Calgary, talked about this tax package. He said, “The Conservative family tax package addresses a current inequity in the tax system, helping all Canadian families with kids.” This is the way we have to look at the different types of opportunities that exist in this bill and the way in which we can enhance them for families.

Again, I know opposition members do not really want to talk about income splitting as being associated with that. I know there is a lot of discussion in which there is mention of it. However, when we look at people with taxable incomes, let us say, of $60,000 for one person and $20,000 for the other person, they would have to pay $1,200 more in federal income tax than a couple that had two children with each spouse reporting a taxable income of $40,000. It is the same $80,000, but we need to take a look at that if it is split. These are great opportunities.