We looked at the data ourselves, and we can't find any rationale for it. There are a handful of countries, mostly small tax havens--Costa Rica, Puerto Rico, that sort of thing. We can't find any rationale. It does bring in more tax revenue for Canada.
Really, to our mind, there is no justification for it other than a potentially historic precedent in the Income Tax Act, which has been changed in other areas, I think in terms of RRSPs.