Thank you, Mr. Caron.
I want to take the next round.
Mr. Broder, I want to discuss your brief. On page 1 of the brief, it says that the CBA
...supports streamlining of regulation to reduce the administrative burden on registered charities and other qualified donees and other measures that promote efficiency and effectiveness in the charitable sector while ensuring that resources available for charitable work are maximized.
Then you have the letter to the Minister of Finance, and under number three you have:
Permitting the legal representative to designate all or part of the Undesignated Gift Portion to be transferred to any testamentary trust created under the individual’s will. The Undesignated Gift Portion would be available to be applied against estate income according to the ordinary rules respecting charitable gifts. However, the estate may have insufficient income to utilize the consequential charitable donation tax credit because the will provides for the establishment of one or more testamentary trusts. The CBA Section believes it is undesirable from a policy perspective that the unused portion of the charitable donation tax credit would be unavailable by virtue of a specific testamentary scheme set out in the will. The CBA Section recommends that section 118.1 be amended to allow the legal representative to designate all or part of the Undesignated Gift Portion as a testamentary trust created under the individual’s will.
I support what you said on the first page, but it seems you're recommending things that are going to be complicating, certainly from an income tax perspective, the regulation of charities. When Mrs. Glover asked you the question, I was a bit unnerved in the sense that it was my question as well. I wanted you to explain how it would affect the will of one individual passing away.
Isn't this a bit of a problem that we're facing? People say to streamline things, not to over-regulate; however, just make these three changes that, in fact, go against the streamlining of the regulation and make it more complicated. You could even apply that to things—whether they're good or bad policy ideas—like the stretch tax credit or the donation of securities, which came up in 2006. It was a good policy idea, but it makes the system more complicated.
That's just a concern I want to raise and have you address.