Thanks, Pierre. Yes, I'd be happy to give my observations.
We've now had experience in the trenches with the TOSI rules. What we predicted is what's happening. We have a lot of difficulty interpreting the rules. They're not just tweaks. If you look at the record, if you look at how many interpretations and positions the CRA has released in trying to help auditors, Canadians and taxpayers interpret the TOSI rules, you get a good idea of the number of resources that are being spent just on learning the rules, not even on enforcement.
When I have a client who calls me about the rules, I have to pull out the act. I will not give an answer over the phone. I have to get back to client and I am a tax practitioner.
The income-splitting objective, I think, was a notable one. As I said in a Senate standing committee comment, I think we could probably collect about 75% of the anticipated revenues from the TOSI rules by changing them to a simple income-splitting curtailing method of extending our kiddie tax age to 24. That would have taken no additional work, with no additional costs of recovery for that.
In the trenches, to answer your question, both the passive income rules and the TOSI rules are problematic, and we're still learning.
I think it was Justice Rip who made the comments that you were talking about. I was at the presentation when he talked about the Tax Court issues, and we're seeing them. I alluded in my opening remarks to the workflow that's moving up to appeals and to the Tax Court.