Thank you to all of the witnesses.
I only have a short amount of time. I'm going to start with Mr. Ball of the chartered accountants.
You used I think the word “unfair” twice, once in reference to the special purpose trust changes that have come in and another time on the changes to section 94 of the Income Tax Act as well.
Was there a public policy reason that you can discern for the fact that special purpose trusts are being taxed in the way you've described, where sometimes the wrong people are being saddled with the tax bill?
In the other context, not grandfathering, if I can call it that, the five years people had the expectation they'd have, were those policy choices, was it negligence, or just simply unfair?