Thank you, Pierre, for the kind comments.
My experience has been that the average accountants and their clients just cannot comprehend these rules nor apply them. At the end of the day, we're dealing with a situation where these rules apply to such a broad-based group of people. Pretty much every single private shareholder of a private corporation will have to deal with these rules and has dealt with these rules, whether correctly or not. That's the problem with these rules: When you foist complexity on such a broad group of people who do not have means to access people like Peter Weissman, me and others, foundationally in my view, that is just unfair.
I agree with your proposition, and I agree with the former justice proposition that the courts will be littered and the CRA will be littered with disputes on these matters, which is very unfortunate. Now having said that, is there a compelling policy need to do something to cleanup some mischief? Absolutely, but not with this set of rules.