Thank you.
I actually have to disagree a little about who's affected.
The way the rules are drafted, everyone is affected. Then you have to figure out whether you get an exception or not. Any family-owned business that pays a dividend to a family member is affected by the rules. The issue is, are you eligible for an exception, or is the dividend reasonable? One of our big concerns is its complexity. One of the joint committee's observations was that it was drafted from the point of view that everybody is in unless you can find an exception. That was one of the joint committee's major concerns, and mine as well.
I think the other aspect you hit on was, how much do people understand, and the natural follow-up of whether or not they will follow the rules. That's the concern about complex tax rules— whether people will comply. First, will they understand them, and then will they actually comply with them? That's our concern about the tax on split income. It is very complex. I think it is broad in terms of who it applies to. Then you have to find an exception or you have to meet the reasonability test.