I'll speak to the TOSI rules first. Ultimately it's just a very complex set of legislation. Whenever we have to decide whether to aim for fairness, horizontal equity, vertical equity or simplicity, sometimes the best answer can include all of those things. We have to choose, and although I agree with some of the things the Department of Finance was looking to do with the TOSI rules, the manner in which they have gone about it has just created too much complexity in the marketplace.
We want our businesses and advisers not to be spending a lot of time trying to figure out who can be paid a dividend: my wife or not my wife? We want to focus their time on growing their businesses. We want the advisers helping them to grow their businesses.
I was looking through some of my documentation and found 30 CRA reviews or notices about the new TOSI rules already. That is a lot considering these are only two years old, and there are still more coming. I don't believe they've responded to all the submissions. When it comes to TOSI, it's a very complex piece of legislation. With the right team I think we could meet Finance's goals, but also simplify the system