Well, first of all, apply GAAR and apply the thin capitalization rules. I'd like to note that in the United States the IRS did apply its anti-avoidance rules against the Canadian income trusts that owned American businesses, so we don't have to be worried about needing to have reciprocity. They taxed us, we tax them; that's the way it works. We both have thin capitalization rules and intercorporate pricing rules to prevent artificial transactions and pricing for the purpose of avoiding tax in our respective countries.
The other point I would note is that a German Institute for Federalism and Intergovernmental Relations study released in August 2006 found that 75% of the OECD countries have thin capitalization rules in place today for non-arm's-length debt transactions within corporations owned by multinationals. They concluded in interviewing the German multinationals that those multinationals use significantly less debt leverage in the country that has the thin capitalization rule, the consequence of which being they pay taxes to those foreign governments.
Thin capitalization rules work; that's why 75% of the countries have them. There's no excuse for Canada not to execute its thin capitalization rules in order to be competitive with the world. They exercise those tax obligations in their countries, so it's reciprocal for us to do the same. We will protect our government tax revenue base for all the various services that we've had a number of speakers seek to get better funding for.
