When I read Bill C-48 as it relates to all the measures the Canadian government is putting forward to address the taxation of Canadian multinationals, one thing is clear. On the one hand, the government really seems to want to end a form of tax fraud involving tax havens. It is targeting taxpayers, ordinary citizens who are not respecting the tax system by putting their money in tax havens. My sense is that the Canadian government wants to crack down on that practice.
On the other hand, however, when it comes to tremendous corporate and personal wealth, the government seems to want to create a legal way to exempt the super wealthy from paying taxes. There seems to be a two-tiered system to deal with the whole matter of tax havens, international transactions and so forth. If you're not a multinational or you aren't super wealthy, the government is watching you, given that a multitude of rules can be applied to stop your aggressive tax planning tactics. But if you're in the opposite position, the government seems to want to make it easier for you not to pay taxes. The upstream loan rules set out in Bill C-48 are an example of the government contradicting itself.