First, when there is a dispute, negotiations are always carried out to reach a settlement. Settlement discussions are not unusual when there are disputes. It is a normal process.
The legislation that the Canada Revenue Agency used to force KPMG to disclose the identity of taxpayers had only just changed. When we went to court, the wording of the legislation had not yet changed. Once in court, we were told that it was not certain that we would be able to obtain the identity of those taxpayers.
The first factor was a legal opinion asking that the Canada Revenue Agency would never know the identity of those taxpayers.
Second, because the schemes went on for a number of years, we found a way to backdate the review of tax returns to 13, 15 and 16 years for some participants, which increased the amount of the bill. We then decided that all taxes had to be paid.
To avoid the risk of losing in court and never knowing the identity of those taxpayers, we agreed to take all the tax returns back 15 to 20 years, which is very rarely done, to get that money and move on, instead of running the risk of getting nothing.