It's offshore, but there is only one of the ten owning a 10% interest who is in Canada, and yet the entire trust is taxable in Canada. As I mentioned, I've had to write letters to some clients saying if any of the grandchildren or great-grandchildren—everyone is now out of Canada—ever think of coming back to Canada, please tell me in advance and we'll have to try to do something, because the entire trust is going to be subject to Canadian tax. It's too late to deal with this in the present iteration, but perhaps it could be dealt with in a future technical amendment.
On March 7th, 2013. See this statement in context.