I would agree with the member that there are a number of tax benefits applicable to small-business owners that were put in place to encourage their growth, encourage employment in Canada through that growth, and assist them in transitioning their businesses into larger operations. That is certainly true.
The IPP legislation operates on several different levels. First, we believe that the small-business owner should be entitled to the same benefits as employees of larger operations, as defined by the rules. On the way the rules work, if you have a three-person plan, for example, they're fully impacted by these rules, but by adding one more member to the plan they are excluded from the rules. If you have a four-member plan that becomes a three-member plan, you fall back into the rules.
There just seems to be an arbitrariness to the rules that adversely impacts these individuals. The RRIF minimum rules are retroactive, in effect. They apply to plans that currently exist, as well as new plans. We don't understand that, given the power of the CRA to deal with this issue already. There are already Federal Court of Appeal decisions that support the CRA challenging the specific concerns they have about accumulation of surplus.
There are also a number of technical issues with the rules that make them very difficult for a small-business owner to comply with and administer. So we see a number of elements of tax fairness in the proposals that we feel need to be addressed.