Good morning to you all.
Good morning. My name is André Lareau. I am a professor of tax law at Université Laval. I was the faculty dean. I earned my bachelor's degree in law at the Université de Sherbrooke, my master's degree at Osgoode Hall Law School and a master's degree in American tax law at the University of Miami School of Law. I also accompanied Radio-Canada to the Isle of Man for the investigation last year.
Tax laws are complex, and the Income Tax Act is very different from what it was several years ago. Why is it so long? The reason is the complexity that has become necessary because of the actions proposed by tax experts, who find a way to create strategies to circumvent measures that require new provisions to counter the provisions implemented by the tax experts.
In 1985, the judgment in the Stubart case indicated that the Department of National Revenue, now known as the Canada Revenue Agency, could not take on a transaction made only for tax purposes when the transaction complies with the other guidelines in the act.
In that regard, the general anti-avoidance provision was created in 1988 and is contained in section 245 of the Income Tax Act. It is understood that this is a general anti-avoidance provision, not an anti-evasion one.
Since I was asked to appear here to speak about KPMG in the Isle of Man, I will humbly submit that the strategy put in place by KPMG does not fit—