Domestically, we have safeguards in place in the sense that we have a GAAR committee that is designed to ensure our domestic GAAR is applied consistently across the country. The hope is that same GAAR committee would also consistently review all applications of the principal purposes test to have those domestic safeguards in place.
As you said, I think CRA's published position to date is that they would apply both at the same time. This would cause a significant increase in tax dispute litigation time and expense, fighting two different rules as opposed to one in determining whether one or the other applies.