As a final word, and I'm sure we'll have an opportunity to come back to this, suffice it to say that the upstream loan rule was an attempt to avoid the residual tax. The residual tax was only imposed when a foreign affiliate distributed a dividend to the shareholder in Canada. If the foreign affiliate made an upstream loan to the shareholder in Canada, which has the same economic effect, then the rule didn't have applications. The upstream loan rule will essentially treat that as a dividend, and then subject to potential—
