Well, we have sent in.... Part of the material I have is an extensive brief that we sent to the Quebec authorities. I'll give you one small example.
We have clients who in 1946, after having survived the Holocaust in Hungary, moved to Mexico and in 1993, at age 73, moved to Canada. The immigration papers show “retired”.
We have no idea what he had in 1993, but we do know that in 2000 there was essentially $5 million with UBS. He died. The widow is now relying on the money. She is not necessarily compos mentis. We would like to clean it up.
We've made a deal with the federal government whereby the tax on the income only for the 10 years would be imposed, with some interest. Quebec is insisting on taxing the opening capital. When we say that from 1993 to 1999 it is absolutely impossible for a 73-year-old to have earned that money, their answer is, we don't care; we're going to tax it.
The fact is that she's relying on that money. We have no alternative but to go to court, and we will take Quebec to court. What's going to happen is that not only will we have the litigation, but people are simply going to move to Toronto, move to the United States—they'll leave it. Because of the bureaucratic position, I think the program faces a significant threat of closing down in Montreal, federally and provincially.
I might add that under the CRA—