I'm happy to speak for a minute.
With respect to the surplus stripping changes that are proposed by the government, there definitely is retroactivity built into those rules. The Department of Finance is receiving a lot of representations on that.
They say that the changes in section 84.1 only apply to dispositions on or after July 18, but that's not true, because you have to look back at all the transactions in determining whether you have a section 84.1 problem. You have to go back and look at all the transactions all the way back to when it was first enacted, I believe in 1984, and that can create some situations where you thought you had proceeds that you could extract because capital gains had already been paid, but now you're going to be forced to pay tax at a dividend rate if you extract those funds out of a company.
It's the same thing with the changes in proposed section 246.1. It talks about the amounts “received” or “receivable on or after [the] Announcement Date”. If you have a transaction that triggered tax beforehand, that triggered a capital gain before the announcement date, but you did not receive the funds until on or after the announcement date, there are problems with the planning right now. We don't believe it's fair. We respect the government's right to change their tax policy in respect to this area, but it should be going forward, not being retroactive—