Let me try to answer your second question first. The changes made to section 94 and subsection 94(1) are perhaps not technical measures or remedial measures per se; however, they have been brought before the House of Commons and the Senate on a number of occasions in the past.
With respect to tax avoidance—perhaps this is because I'm on this side of the table—I would suggest that subsection 94(1) goes very far, and, as you see in my submission, it perhaps goes too far in taxing some trusts that have a very ephemeral relationship to Canada. If a wealthy Canadian leaves $1 million—$100,000 to each of his 10 grandchildren, nine of whom live in the United Kingdom and one who lives in Canada—then Canada gets tax on the Canadian's portion. If, however, he leaves it in a single trust for them, the full $1 million is taxable in Canada.