Just quickly, the voluntary disclosure program is primarily targeted at Canadians who want to come forward. Often it happens with an estate. One generation of a family passes away. The next generation has this wealth that they weren't expecting, but they find out that it wasn't tax-compliant and they want to move forward in compliance with the law. That's who that is for.
In terms of legal settlements, usually the CRA is already on the case, either with a specific taxpayer or through an unnamed persons requirement. That's a very different setting. Through those legal agreements we will seek to assess the facts and reach an agreement in cases in which it makes sense for the taxpayer. In some cases we won't, because the offer isn't there. In other cases, the principle or the precedent is so important that the agency won't come to an agreement.