I'll deal with the first part first.
My understanding is that they—“they” being the Finance people who developed the rules—wanted to prevent certain types of planning that was happening, and one of them was planning with Alberta resident trusts. They didn't want people to be able to have the income taxed in the trust. That was a valid concern.
I guess the flip side of that is that there are a lot of these trusts that are set up that aren't in Alberta, and they really aren't set up for tax purposes at all. That was the debate around that.
On the section 94 changes, we fully recognize that the government has the right to change the rules. It's its right, its ability. But at the same time, the non-resident trust rules had gone through a lot of change, and that five-year rule had remained at the end of the day and then was eliminated more recently. We just believe it's unfair. Where you rely on something that's an inherent part of the tax system and actually plan to be inside of it, you should get grandfathering in the situation.