Yes, exactly. Who's right?
We know that you're just doing the legal analysis. We've come up with a different answer than the Department of Finance has. It doesn't mean that the Department of Finance is wrong, but if we look to other jurisdictions such as the U.K. and how they've dealt with this, we see that the U.K. has taken a much different approach. Their definition of financial institution, specifically as it relates to private trust, is very, very close to the definition that we find in the Treasury regulations.
There have been a number of U.S. treasury department officials who have come out and officially stated that they know model 1 IGAs are dependent upon domestic law for implementation. Canada has a model 1 IGA. But we expect domestic legislation to very closely follow the Treasury regulations, and that's what the U.K. has done.
Canada has not followed the lead or the analysis set forth in the Treasury regulations. One Treasury official even said that there should be very little daylight between domestic legislation and the Treasury regulations as they relate to these various definitions.