The way the system works now is that facilitators develop and market tax-planning products to prospective clients, implement them, and hope that they're compliant. As it turns out, as we've seen, what ends up happening in some of these cases is that years later these tax-planning products, which are otherwise secret, come to light through a leak or a whistleblower, and the system has to engage in a very costly process of, essentially, litigation. If a tax product is registered in advance and vetted to, say, see if it complied with the GAAR or something of that nature, then there would be no risk to that client. If it's approved in advance—it could even be done in a confidential way—the tax-planning products can be put in place, clients can optimize their tax, and the government isn't short tax that's owed. It's in place in the United States already. It's one of the recommendations that the OECD has made as part of the BEPS action plan.
