Well, the policy recognizes that it is within the domain of the other jurisdiction to tax corporations that carry on business inside their borders in the same way that it is up to Canada to impose taxation or not on subsidiaries of foreign parent companies that are resident in and carry on business in Canada.
For example, if you had a subsidiary of a foreign corporation that carried on business in Canada, and that corporation was resident in Canada, then Canada would have first ability to tax that corporation. We regard the same thing bilaterally with our tax treaty partners and also with our TIEA partners.