If I could perhaps add, as has been stated, this is a very complex subject area. Perhaps it would be useful to provide a more concrete example to get at your comment—and again follow up on some of Mr. McLeod's questions—of a situation to which we might think that the protections afforded under the MLI might apply.
My colleague, Stephanie, mentioned some previous tax cases that had been lost by the Crown where the tax planning involved was the kind of tax planning this bill is seeking to prevent. In one such case, you had a Cayman Islands corporation that had shares of a Canadian company. If it had sold those shares, it would have been subject to Canadian tax because, of course, Canada does not have a tax treaty with the Cayman Islands that would have exempted it. The fact of Canada's having a tax information exchange agreement with the Cayman Islands isn't relevant, because the TIEA would not have provided that tax exemption on the sale of the Canadian shares.
What the company did then was essentially move or continue into another jurisdiction, Luxembourg, with which Canada does have a tax treaty, in order to avail itself of.... The Crown's position was that it was in order to avail itself of the benefits of that treaty and, as such, to avoid Canadian tax on the disposition of the Canadian shares. I forget the exact quantum in dispute of taxes. It strikes me that it may have been in the tens of millions, although that's something that we can look into and get back to the committee with.
These are some of the sorts of transactions that we have seen and that we have challenged and that we would hope that the multilateral instrument would address. Again, hopefully that example highlights in a practical, real-world situation the differences between the benefits afforded under a tax information exchange agreement and one of our treaties.