Evidence of meeting #122 for Finance in the 41st Parliament, 1st Session. (The original version is on Parliament’s site, as are the minutes.) The winning word was countries.

A video is available from Parliament.

On the agenda

MPs speaking

Also speaking

Garth Manness  Chief Executive Officer, Credit Union Central of Manitoba
Laura Eggertson  President, Adoption Council of Canada
Martin Lavoie  Director of Policy, Manufacturing Competitiveness and Innovation, Canadian Manufacturers and Exporters
Richard Paton  President and Chief Executive Officer, Chemistry Industry Association of Canada
David Phillips  President and Chief Executive Officer, Credit Union Central of Canada
Karen Proud  Vice-President, Federal Government Relations, Retail Council of Canada
Mike Moffatt  Professor, Richard Ivey School of Business, As an Individual
Rob Cunningham  Senior Policy Analyst, Canadian Cancer Society
Ron Bonnett  President, Canadian Federation of Agriculture
James Laws  Executive Director, Canadian Meat Council
Karen Cohen  Chief Executive Officer, Canadian Psychological Association
Yves Savoie  President and Chief Executive Officer, Multiple Sclerosis Society of Canada

8:45 a.m.


The Chair Conservative James Rajotte

I call to order the 122nd meeting of the Standing Committee on Finance. I want to welcome all of our guests here this morning.

Our orders of the day, pursuant to the order of reference of Tuesday, May 7, 2013, are to study Bill C-60, An Act to implement certain provisions of the budget tabled in Parliament on March 21, 2013 and other measures.

Colleagues, we have six people who will be presenting, five here in Ottawa, and one, I understand, by teleconference from Winnipeg.

Mr. Manness, I just want to check with you first. Can you hear me okay?

8:45 a.m.

Garth Manness Chief Executive Officer, Credit Union Central of Manitoba

Yes, I can.

8:45 a.m.


The Chair Conservative James Rajotte

Welcome to the committee.

8:45 a.m.

Chief Executive Officer, Credit Union Central of Manitoba

Garth Manness

Thank you.

8:45 a.m.


The Chair Conservative James Rajotte

We'll present in the following order. We'll start with the Adoption Council of Canada and its president, Laura Eggertson. Welcome to the committee.

We also have, from the Canadian Manufacturers & Exporters, the director of policy, Monsieur Martin Lavoie.


8:45 a.m.


Raymond Côté NDP Beauport—Limoilou, QC

Excuse me, Mr. Chair, but we have no interpretation.

8:45 a.m.


The Chair Conservative James Rajotte

I understand that the translation is working now. Thank you.

From the Chemistry Industry Association of Canada, we have the president and CEO, Mr. Richard Paton. From the Credit Union Central of Canada, we have the president and CEO, Mr. David Phillips. Welcome to you.

From the Retail Council of Canada, we have the vice-president, Ms. Karen Proud. Welcome to the committee.

And by teleconference we have, from the Credit Union Central of Manitoba, the CEO, Mr. Garth Manness.

Each of you will have a maximum of five minutes for an opening statement, and then we'll have questions from members.

We'll begin with Ms. Eggertson, please.

8:45 a.m.

Laura Eggertson President, Adoption Council of Canada

Thank you very much.

Good morning, Mr. Chair and committee members. Thank you for inviting me to address you today.

My name, as you've heard, is Laura Eggertson. I'm the volunteer president of the Adoption Council of Canada. I'm also here as an adoptee and an adoptive parent.

We hope that the changes to the adoption tax credit that the federal government introduced in this budget will encourage and support more families who are adopting.

As the budget document mentions, there are about 30,000 children and youth in foster care across Canada who don't have permanent families and are legally free for adoption. Many of them are aboriginal.

Only about 2,000 children and youth are adopted from foster care every year in Canada. About 1,000 children are adopted privately, and another 2,000 or so arrive from other countries and are adopted internationally.

These tax credit changes extend the time period in which adoptive families can claim expenses related to an adoption. When you adopt through the public system, there is not, generally, a cost. But some parents may get their home studies done privately, which they pay for. They also have to undergo pre-service training, which may be a course that is essentially about adoption and parenting. Those expenses are things that now can be covered under this tax credit change.

In Alberta, for example, families may spend $12,000 a year to adopt privately. Previously, families could only claim those expenses in the year they occurred, even if it was several years before the adoption took place. That left many people unable to receive the full benefit of the tax credit, which is a 15% credit, this year, on up to $11,669 worth of eligible expenses. Now families will be able to claim all the expenses in the year they adopt, no matter when the expenses occurred.

You may wonder whether this is an important change. To us it is important, not just for the way it will offset adoption expenses but also because it sends a message that the federal government cares about our Canadian children and teenagers who don't have permanent families.

These young people come into foster care through no fault of their own. We take them into care without their consent, but for their protection. We remove them from family members they love. We separate them from their brothers and sisters—or we may. Then we shift them around from home to home, often for the rest of their lives. Traumatized and grieving, they spend those lives trying to adjust to each new home and new family. They wonder how long each one will last—and most of them won't last.

Youth “age out” of foster care at 16, 18, or 21, depending on their circumstances and their province. That's when we consider them old enough to manage on their own, without permanent families to support them and celebrate the milestones in their lives. One 21-year-old graduate of foster care recently asked me, “Who will come to my university graduation?”

All of us as parents know that children need our support long after they have turned 18. They may need us even more after 18, as they struggle with attending college or university, finding a job, and starting their own families, especially in this economy.

Without permanent families, many youth who age out of foster care end up homeless. They come in contact with the justice system. They live on social assistance, become teen parents, and may see their own children in foster care. The cycle continues.

At the Adoption Council of Canada, we believe we need to change the system to make it easier for Canadians to adopt children and youth of any age, or to make other permanent connections through kinship care, legal guardianship, or customary care. One young man, at age 17, told us recently, “I just want parents who will tuck me in at night.”

These changes to the adoption tax credit are a first step. We believe there is a strong leadership role the federal government can play. We look forward to continuing to work with the government in the coming months and years on more ways to encourage adoption and permanency. So we ask the committee to support these changes to the tax credit in the budget bill.

I would be happy to answer any further questions. Thank you.

8:50 a.m.


The Chair Conservative James Rajotte

Thank you very much for your presentation.

We will now go to Mr. Lavoie.

8:50 a.m.

Martin Lavoie Director of Policy, Manufacturing Competitiveness and Innovation, Canadian Manufacturers and Exporters

Thank you, Mr. Chair.

Thank you, Laura.

Thank you for inviting me today to discuss Bill C-60, the Economic Action Plan 2013 Act.

On a general note, our organization and our members were very pleased with the recognition in the budget of manufacturing as an important driver of our economy, when it comes to innovation, research and development, exports, and value-added activity.

The budget partially responds to some of our priorities that were identified in our pre-budget submission. I will focus here on three: the accelerated capital cost allowance, which is a tax incentive for the acquisition of machinery and equipment; labour training and facilitating the hiring of foreign workers; and new direct support for manufacturing, research and development, and innovation.

Let me start with the ACCA. This is by far the most popular measure among our members. The ACCA, which has been in place since 2007, has boosted Canadian manufacturers' investments in machinery and equipment by 45% between 2009 and 2012.

In fact, Canadian manufacturing investments and all capital assets have surpassed the United States, in both 2010 and 2011, for the first time since 2006. There is still a lot to do, but we're happy to see that these tax incentives are working well and are meeting their objectives.

Let me talk a bit about labour training. It shouldn't be a surprise to anybody that we're strong supporters of the Canada job grant that was introduced in the budget. In our last three budget submissions, we have strongly recommended that the government introduce a tax credit to support the training of new hires and to increase the skill levels of existing employees.

The second part of the challenge, of course, that our members face is the hiring of foreign workers to fill labour shortages that are not being addressed by the domestic labour supply. While we're working with the governments to make appropriate improvements to the program, we're concerned with the manner that user fees will be managed for the labour market opinions under Bill C-60. Division 9 of part 3 of the bill states that the fees to be charged for labour market opinions will be exempt from the User Fees Act.

While I haven't received any confirmation from government officials so far with regard to the meaning of this, I presume that this means that the government would not consult stakeholders on the level of the fees charged, they would not be bound to ensure that service standards are tied to the fees, there wouldn't be, necessarily, any impact assessment, no tabling or publication of proposed new fee structures, etc.

CME, as a whole, has generally agreed that it is reasonable to pay user fees, but not under these conditions. The User Fees Act was established specifically—because of the abuse of user fees by government departments and agencies—as a way to increase revenues to cover off cost, rather than finding more efficient ways to deliver services, or working on the street to establish effective user fees. This clause sets a very bad precedent, in our view, and we strongly recommend that the fees charged for labour market opinions not be exempt from the User Fees Act.

Finally, I would like to comment on the new direct support mechanisms for business innovation that were announced in the budget. As you remember, last year the government told the industry that this $660 million cut under the SR and ED program would be reinvested entirely in new direct funding for business R and D. The government has done it. But there are still a lot of questions with respect to equity of access to this funding across industry sectors, and across the nation.

While we support the new funding provided to the automotive, aerospace, and forestry sectors, in particular, as well as the new advanced manufacturing fund for southern Ontario manufacturers, we must realize that going from the broad taxed base approach, like SR and ED, to a direct funding mechanism is going to penalize manufacturers that do not match these geographic and industry criteria.

We're hopeful that the government will eventually ensure that these direct funds for business innovation be accessible across the country, and across various manufacturing sectors. We're very concerned that the significant reductions that we'll see in the SR and ED tax credit until 2017 will have a detrimental impact on business innovation.

I'd like to conclude by recognizing that this budget is a great step toward a better recognition of the importance of manufacturing for our economic growth and for our capacity to innovate. However, a lot of work remains to be done to ensure that government policies do not discriminate against certain sectors, or certain regions of the country.

We're confident, however, that the government shares our concerns, and we'll work together toward achieving these objectives.

Thank you.

8:55 a.m.


The Chair Conservative James Rajotte

Thank you very much for your presentation.

We'll hear from Mr. Paton, please.

May 21st, 2013 / 8:55 a.m.

Richard Paton President and Chief Executive Officer, Chemistry Industry Association of Canada

Thank you very much, Mr. Chairman, and my thanks to the committee for this opportunity to speak to you.

I think the CME has covered most of the general issues, particularly the focus on manufacturing. So I'll just focus on the ACCA and its importance to our particular industry. This is the two-year extension of the accelerated capital cost allowance for manufacturing machinery and equipment.

This amendment is welcomed by our member companies as a strong signal that this government recognizes it can play a vital role in stimulating investment and growth in the chemistry industry and other industries, and more broadly in the manufacturing sector in Canada. The extension of the ACCA is a key factor that contributes to improving our global competitiveness, and it has strengthened the business case to win new investments in Canada.

In fact, this committee and the Government of Canada have undertaken a number of positive initiatives over the last few years, including corporate tax reductions, capital tax, harmonization of tax with the provinces, and the GST. All of these are complemented by the ACCA change, which is focused on large capital investments.

Chemistry companies credit the ACCA as being a key factor in their decision to invest approximately $3 billion over the last four years. This has resulted in revitalizing the chemistry industry, creating jobs and prosperity in key regions of the country.

For example, in Sarnia, Ontario, two CIAC members, NOVA Chemicals and BioAmber, have made recent investments of $250 million and $120 million respectively. If any of you have been to Sarnia in the last few years, you'll know there hasn't been much investment there for about 20 years. This is the beginning, we hope, of a new trend.

In other regions of Ontario, the ACCA has enabled companies such as Sitech, BASF, and DuPont to expand and improve their facilities.

In Alberta, Williams Energy, Dow, Shell, and Methanex have made investments estimated at $500 million.

NOVA Chemicals will be hosting a groundbreaking ceremony on June 7 for a $1-billion polyethylene facility, which is expected to be up and running in the fall of 2015. They will benefit significantly from the ACCA, and it has made a difference in that investment.

All these investments are a strong testament that clearly demonstrates that the ACCA supports growth and investment and creates jobs and prosperity.

It is also stimulative, and in our view it attracts investment that would not normally go to Canada. Why is that the case? Given the shifts in the global economy and the discovery of shale gas, or the use or development of shale gas, our major competitor now for the petrochemical industry is the United States. They have a very different tax structure from what we have. They have what's called a 60% declining-balance tax structure, where they can, on a permanent basis, write off these major investments over about three years. Without the ACCA, we'd be competing against that kind of investment. They also have a partnership structure that looks a lot like the income tax trusts that the government eliminated—it allows people to actually make the investments without any corporate tax because they flow through the investments to individuals.

I'm not advocating, and our industry doesn't advocate, these kinds of measures in Canada, but we believe that the ACCA does, to a certain extent, level the playing field, at least for the next two years while it's being extended.

However, I would caution that in the long term, for longer-term investments, we are still dealing with this competitive situation vis-à-vis the United States, so we'll continue to work with the government on making sure that we have a competitive tax regime that will attract these major investments to Canada.

In conclusion, we'd like to note that we certainly support this budget and the ACCA measures. In fact, we're part of a coalition of 40 companies and associations that all supported it. I'd also like to mention that it was the number one recommendation of the manufacturing committee that Mr. Rajotte chaired several years ago.

Thank you.

8:55 a.m.


The Chair Conservative James Rajotte

Thank you.

I appreciate that. It was back in 2007, yes.

8:55 a.m.

President and Chief Executive Officer, Chemistry Industry Association of Canada

Richard Paton

There's some corporate memory here.

8:55 a.m.


The Chair Conservative James Rajotte

There's some corporate memory here, yes.

Thank you, Mr. Paton.

We'll hear from Mr. Phillips.

9 a.m.

David Phillips President and Chief Executive Officer, Credit Union Central of Canada

Mr. Chairman and committee members, I'd like to thank you for this opportunity to appear before the committee regarding Bill C-60 and to explain why the credit union system opposes the tax increase on credit unions contained in the bill.

We oppose the tax increase because it disregards the nature of credit unions and the vital contribution that credit unions make to providing Canadians with service, choice, and competition in the Canadian financial services market.

Credit unions are different from commercial banks because they are cooperative financial institutions, and this is fundamental. A commercial bank is owned by its shareholders, and most customers of a bank are not shareholders of the bank. A credit union is owned by its members who are its customers. More than five million Canadians outside of Quebec are credit union members. When the membership of the caisses populaires in Quebec is included, more than 11 million Canadians are members of cooperative financial institutions.

A credit union serves the needs of its members. Commercial banks aim to maximize profits for their shareholders. Credit unions aim to maximize service for their members. The cooperative business model is a service maximization model. It is through a commitment to member service that credit unions bring investment and innovation to local communities across Canada.

Both commercial banks and credit unions need capital in order to grow. Commercial banks can source their capital from public capital markets. Credit unions must source their capital from their members and from retained earnings. The members are the owners, so the members supply the capital directly or through the earnings retained by the credit union. A credit union typically acquires in the range of between 75% and 80% of its capital from retained earnings. The income tax increase on credit unions, therefore, is growth limiting. It deprives credit unions of income that might otherwise be used to support the growth of the credit union by building its capital base. The credit union will, therefore, have less capacity to make loans to small business, fund community economic development, and meet member needs.

Credit unions are relatively small financial institutions that offer a full range of financial services to their members in over 1,760 physical branch locations across Canada. In hundreds of these communities, credit unions and caisses populaires are the only financial institutions that are physically present in that community, employing local residents and serving the needs of local small businesses.

Credit unions are 100% Canadian owned. They serve the financial needs of millions of individual Canadians and they employ over 27,000 Canadians in communities across Canada.

Credit unions are the most important source of competition to the large commercial banks in the overly concentrated Canadian financial services industry. We note comments that seek to defend the tax increase as creating a level playing field. This is a narrow technocratic view. The tax increase disregards the nature of cooperative financial institutions. It disregards the federal government's desire to support small business in local communities and it disregards the federal government's policy objective, stated elsewhere in the budget, of creating more competition in the Canadian financial services sector. A lower tax rate paid by credit unions is good public policy because a lower tax rate for credit unions promotes competition in the Canadian financial services marketplace.

The six large Canadian commercial banks made $30 billion in profit in 2012. The entire Canadian credit union system made less than 3% of that amount in that year, yet the federal government is increasing the income tax of credit unions. This simply does not make sense.

Mr. Chairman, those are my remarks.

9 a.m.


The Chair Conservative James Rajotte

Thank you, Mr. Phillips.

We'll now hear from Ms. Proud, please.

9 a.m.

Karen Proud Vice-President, Federal Government Relations, Retail Council of Canada

Thank you, Mr. Chair. I'd like to thank you and the committee for inviting the Retail Council of Canada here today on Bill C-60.

Today I have the privilege of speaking for an industry that touches the daily lives of Canadians across this country and one that is a critical component in Canada's economic well-being. We are the largest employer in Canada, providing employment for more than 2 million Canadians and contributing more than $75 billion to Canada's economic well-being. The RCC represents more than 45,000 storefronts of all retail formats across Canada. This year, we celebrate our 50th anniversary of being the voice of retail for Canada.

Today I plan to focus my remarks on part 3 and division 1 of the bill, as well as more generally on product tariffs and the government's plan to review the general preferential tariff.

I'd like to start by thanking the minister and his officials for eliminating the tariffs on baby clothes and sporting equipment. We look at this as a pilot project and believe that this is just a first step in a much broader exercise to address all outdated and unnecessary tariffs. We are committed to working with the government to demonstrate that when tariffs are eliminated, Canadians will benefit from lower prices.

With regard to the bill itself, the RCC does have some recommendations for additions to the list of products that should be added to this pilot project. We feel that some items were missed when the review was taking place on baby clothing and sporting equipment, and we've prepared a comprehensive list of these items, which I will provide to the clerk for your consideration. The items on the list include specific athletic footwear, such as soccer shoes, as well as protective headgear for a variety of sports.

As mentioned, we believe this to be just a first step in addressing the tariff issue. The minister has indicated a willingness to look at further tariff eliminations, and the Standing Senate Committee on National Finance, in their recent report on the Canada-U.S. price gap, also recommended that the minister look at the tariffs and do a complete review.

In fact, we believe that this committee should be tasked with undertaking that review. We feel that it would actually be a fairly simply exercise. The committee could look at the 1,400 pages of the Customs Tariff—2013, line by line, to see if there is little or no domestic manufacture of those products. If so, that tariff should be eliminated. If this were to happen, the Retail Council's concern with the proposed review of the general preferential tariff and the effect on Canadian consumers would be greatly, if not completely, eliminated.

This brings me to my comments related to the proposed review. While we understand the government's policy intent whereby countries like China should not be given preferential tariff treatment to boost their export capacity, we do have concerns with its implementation and scope, which we've relayed to the minister's office and to the department.

To address these concerns, we've asked the government for four things. We've asked for more time. The process for sourcing products internationally is highly complex and takes time. We greatly appreciate that the government listened to us during their first round of consultations on this and has already extended their proposed timeframe from mid-2014 to January of 2015. But if retailers have any chance of finding other sources of products, they need at least two years to implement these changes, so we've asked for more time for that review.

We've asked for specific product exemptions. We feel that for some products where there are no alternative sources of products, and where these products represent a staple and a requirement for Canadians—things like canned tuna—they should be exempt from the changes to the general preferential tariff.

9:05 a.m.


The Chair Conservative James Rajotte

You have one minute.

9:05 a.m.

Vice-President, Federal Government Relations, Retail Council of Canada

Karen Proud

We've asked that the rules of origin for products sourced from least developed countries be changed to minimize the impact of these changes on those products. We appreciate the government's commitment to starting to look at the rules of origin for textiles and apparel.

Finally, we've asked that subsequent reviews, currently planned for every two years, be done on a 10-year cycle to allow for certainty for our retailers entering into international contracts.

With that, I'd like to thank the committee for allowing me to raise these issues in relation to the bill. I welcome any questions you might have.

9:05 a.m.


The Chair Conservative James Rajotte

Thank you for your presentation.

Mr. Manness, we'll now go to you for your five-minute opening statement.

9:05 a.m.

Chief Executive Officer, Credit Union Central of Manitoba

Garth Manness

Thank you, Mr. Chairman, and committee members, for providing the opportunity to appear before you today to offer the perspective of Manitoba credit unions on Bill C-60, specifically the measure to phase out the additional deduction for credit unions.

Credit unions are an important part of the economic fabric of Manitoba. The province's 40 credit unions have 191 branches in 117 distinct communities, serving the needs of local consumers, businesses, and farmers. In 67 towns and villages, the credit union is the only financial institution operating to serve the community.

Many credit union branches are in communities that other financial institutions vacated because they were not deemed profitable enough. Our business model, paired with fair tax policy, like the additional deduction, has made it possible and attractive for credit unions to grow in places where our competitors have retreated. Although credit unions have a profit-for-service mandate, not the service-for-profit mandate of other financial institutions, they do need to be profitable to remain viable. That income is their primary source of funds with which to build capital. It is also an important source of funds for key investments in new technology and new services, which they must make to be competitive with the much larger chartered banks.

Since the financial crisis, regulators have been increasing the reserve capital requirements for all financial institutions. Despite the fact that credit unions performed very well during the crisis, stepping up to meet consumer and small business lending demand when other financial institutions stepped back, they are not immune from the higher capital requirements. As Mr. Phillips mentioned, the bulk of credit union capital comes in the form of retained earnings, which come from net income. In order to meet higher capital requirements credit unions need to increase net income by increasing margins, which means being less competitive on rates; by increasing service fees, which means increased costs for our members; or by reducing expenses, which could eventually mean a reduction in service and, potentially, job losses

The removal in Bill C-60 of the additional deduction for credit unions will simply compound the impact of regulatory demands by requiring credit unions to pay a higher portion of their net income in federal tax, and further reduce their ability to build capital, invest in new technology, and stay competitive. The decision to phase out the additional deduction comes at an extremely challenging juncture for the financial services industry. Speaking for credit unions, our members face increasing competition from large, powerful institutions, including federal crown lending agencies, a monetary environment with unprecedented low interest rates, which are driving low margins and reducing interest income; and increasing levels of compliance, which disproportionately impact smaller financial institutions like credit unions.

Now credit unions alone face the possibility of having to pay more of their net income in federal tax. Just as the banks did before us, it is no exaggeration to say that some people may begin to question the future viability of credit unions in many communities in rural Canada. Not only could people be left without access to a nearby financial institution, valuable and stable jobs at the credit union could be lost.

According to our analysis, based on 2012 financial results, 21 credit unions in Manitoba benefited from the additional deduction. Those credit unions have branches in 50 Manitoba communities, where the credit union is the only financial institution. The impact of removing the additional deduction, once fully implemented, would be $4.5 million per year. This may not seem like a large amount, but to the credit unions working with narrow margins and increased regulatory requirements and service needs of their members, it certainly is.

Removal of the additional deduction for credit unions, as proposed in Bill C-60, is characterized as closing a tax loophole. A loophole, by definition, is an ambiguity in the wording of contract or law that provides a means of evading compliance. The additional deduction for credit unions was never a tax loophole by definition or design. It was an intended feature of tax legislation, created when credit unions first became taxable in 1972, designed to help credit unions retain capital to meet regulatory requirements and to grow, thereby to provide effective competition in the financial services industry, a goal that this government and credit unions share.

Although the financial landscape is different from 1972, the need for this deduction to help qualifying credit unions accelerate the growth of the retained earnings continues to exist. Since the deduction was introduced in 1972, it has functioned exactly as intended.

I would argue that this tax deduction has proven to be good public policy. If it were to remain in place, it would continue to be good public policy as it will help credit unions provide effective financial services that can assist with the federal government's stated desire to increase competition in this sector. It would also represent good public policy by helping to maintain strong financial services in as many communities as possible and helping to contribute to the sustainability of the many communities in rural Canada where credit unions are the only financial institutions.

For these reasons, Mr. Chairman, I respectfully ask the committee and the federal government to reconsider this proposed change.

9:10 a.m.


The Chair Conservative James Rajotte

Thank you, Mr. Manness, for your opening statement.

We'll now go to questions from members.

We'll begin with Ms. Nash.

9:15 a.m.


Peggy Nash NDP Parkdale—High Park, ON

Thank you, and good morning to everyone. Thank you all for being here today.

I'd like to start with the two representatives of the credit unions. Both of you have drawn a picture of the credit union sector being significantly different from the banks—in their size and community reach, in community support and investment, and in the fact that they are not for profit and owned by their members.

Mr. Phillips, you pointed out that the six largest banks made $30 billion last year in profits. If the profits of credit unions are just 3% of that, I can't imagine that the banks feel threatened by the credit union sector. When you were consulted by the federal government about these changes prior to the budget being brought in, what was the rationale of the government and your response?

9:15 a.m.

President and Chief Executive Officer, Credit Union Central of Canada

David Phillips

I'll answer first. Thank you for the question, Ms. Nash.

We were not consulted on this change. I think that was actually indicated by the officials when they appeared before this committee last week. I know that when the budget is close to being prepared, typically one would not be consulted on a specific tax change.

But we need to remember that this provision has been in place for 40 years. If there was a feeling in the department that this wasn't working the way it should—I don't think they just dreamed this up—they could have called us two years ago, or five years ago, and there could have been a discussion on this. There's been absolutely no discussion on this change whatsoever.