Sure. My concern is that those changes, the permanent establishment changes in particular, in my view, would be significant changes to our tax treaties. They're not just minor changes that would only affect a couple of companies and a couple of industries. It could affect virtually all cross-border businesses and could result in Canadian companies having to file tax returns, for example, in many countries around the world and having many countries around the world having a right to tax those Canadian profits.
Also, then, in many cases it could result initially in double or triple taxation or an infinite level of taxation. It would result in much more administrative compliance and much more difficulty in determining where your profits ought to be allocated, but also in many more disputes and, as I said, to the extent that profits are allocated to those foreign countries, it could result in a loss of revenue in Canada.
I think the reason that many countries have reserved on those rules is really for those exact reasons.
I think these are only the countries that would be confident that they would always win on expanding the PE threshold because, obviously, investment can be inbound and outbound. If a country is of the view that you're always going to win—perhaps if it's not resource-rich, for example, I guess, or if they think there are more capital inflows than outflows—then they might be inclined to make those changes.