I would agree with that. I believe the withholding tax is sufficient where it is. I don't believe there is a leakage to the U.S. investors. The other thing to consider is this. You're talking about effective tax rates of equivalent numbers using 7%. If you look at the average effective tax rate that corporations pay—this is on a broader sense, looking at business trusts—it's effectively 22%, on average, but that's off income.
We've looked at 83 business trusts that we cover at BMO Capital Markets, and on average distributions are 1.5 times the size of taxable earnings. It's a bigger number. You're collecting 15% off a bigger number. In fact, if you work through the math, it works out to about 23% that they collect today on withholding taxes off earnings going to the U.S., on average, versus an effective 22% rate.
I don't believe the withholding tax to the U.S. non-residents is a big issue at this point. I think it's something we could review. In my research I have also found that the withholding tax on U.S. flowthrough entities is specifically exempted from the tax treaties. In fact, they're collecting anywhere from 30% to 35%, depending on the entity you're dealing with. The U.S. is withholding more tax from non-residents. It's certainly an area I would think could be revisited on Canada's behalf.
