Well, to respond to that question, the way the tax is made refundable to beneficiaries is that the distribution that's made to a Canadian resident and that has been subject to this tax at the trust level is deemed to be a dividend eligible for the dividend tax credit. As a result, they're credited with the dividend tax credit at the individual level.
That's the mechanism for the refund. Unless that mechanism is changed somehow, it will be refunding at a 31% rate, even though, under this proposal, I think the tax would be applied at a 10% rate.