I think it's basically separate from transfer pricing. We do not have a GAAR. I'm quite familiar with both the Canadian GAAR, the New Zealand GAAR, and the Australian GAAR. There are problems with GAARs, because although they sound wonderful in general, you still need standards for what is abuse. I mean, the GAAR doesn't exempt you from having to think through the application of the rule in particular cases.
We have economic substance in our law. We have the rule that transactions will be disregarded unless they have economic substance.
It used to be a purely judge-made law. It came out of our courts and was around for probably 60 or 70 years. It was enacted into our Internal Revenue Code in March of 2010 as paragraph 7701(o) of our Internal Revenue Code. We'll see; it's too early to see how that's going to play out.
But I think it is, certainly in your terms, similar to a GAAR.