As I said in my remarks, we looked at ways, and we've had discussions and consultations with a number of stakeholders, including officials and parliamentarians, on how we move forward this discipline. The endgame for us is having a discipline of bringing forward tax legislation on a regular basis, on an annual basis or every two years. That's our objective.
Then we have to go to the issue of how do we get there. We looked at what happens in other countries, and this is where we were attracted to this notion of a sunset mechanism, which would trigger bringing forward legislation or the legislation is deemed to never have been proposed. When we say “never have been proposed”, tax practitioners or tax professionals tell us that could create quite a mess.
But on the other side, there's quite a mess being created here. There's one measure contained in this bill that dates from 2002 and potentially could affect 18,000 taxpayers. It's with respect to donations. In this measure—and it went before the Federal Court of Appeal—the taxpayer was assessed, but the court established that the taxpayer had no appeal rights. It's a matter of fairness when this legislation is not brought forward. What the Federal Court of Appeal said in this matter is that there needs to be some form of retroactivity in terms of fiscal policy. That of course we accept. To be effective, there has to be some form of retroactivity. But the courts also said that doesn't take into account the length of time. The retroactivity assumes there is a limited amount of time.