On the considerations that inform whether we have an exemption or credit system, with an exemption system we end up having a neutrality between us and other foreign competitors in relation to foreign investment. We don't have an additional Canadian tax, current or deferred, that'll apply to Canadian investors carrying on foreign operations. The counter to that is we lose neutrality in relation to the taxation of Canadian income versus the taxation of this foreign income.
The system Canada has had in place with treaty countries for approximately 35 years is an exemption system. We won't impose any current tax, and we won't impose any tax on the income when it's brought back.
Other countries, including some of the largest countries in the world--the U.S., the U.K., and Japan to a considerable extent--have the same deferral opportunity. They do not tax foreign business income of their companies' foreign affiliates as it is earned. It remains non-taxable by the U.S. as long as it's left outside of the country. If and when it is returned to the country it is subject to tax, with a credit for any underlying tax.
If the foreign affiliates of those U.S. companies, for example, invest outside of the U.S. and generate business income outside of the U.S., they are able to leave that income offshore free of U.S. tax. But when they bring it home they are subject to a potential 35% tax. That has led many U.S. companies to not bring the income home, and a couple of years ago there was what could be described generally as a tax amnesty by the U.S. to have companies bring the income home so it could be employed in the United States.