There are two specific concerns. One is that because we're introducing this identical wording in so many treaties around the world, I think it subjects Canada to the uncertainty of following tax decisions of foreign countries around the world interpreting the identical provision in similar circumstances. It adds more uncertainty in international jurisprudence and how it might interpret it. Also, with our domestic general anti-avoidance rule, we have a few decades of jurisprudence. We know when it applies. We know who has the onus for proving different things. The onus is on the Crown to show the object and purpose of a particular rule under our domestic rules. That's appropriate because the Crown is drafting those rules. They're in the position to know the object and purpose.
In the multilateral instrument, it's unclear who has the onus of proving that. I think that's just one example of additional uncertainty that will arise, because if a taxpayer has to prove the object and purpose of a particular treaty provision, that will be very difficult because the taxpayer wasn't the one who negotiated the treaty to begin with. I think the onus should remain on the Crown, but it's unclear how that will be interpreted.