I still think that answer would give no comfort to a small business owner who gets a letter from the agency with a demand for papers. That small business owner has to immediately drop everything and call their lawyer or accountant, or both, and in many cases for seemingly frivolous items.
Yet, I understand the point that in a large case that will be going to court, you need to gather the evidence, but there's a perfect opportunity there for the large tax filer—the overseas tax filer—to game the system through delay, because it's indulged by the agency.
We've heard about the KPMG case. We were talking about the Panama papers and the Paradise papers here. Have there been any convictions in the Panama papers and Paradise papers cases so far?