Yes. The U.S. law covers payments to the U.S. government as well.
A major point of the intent of the law is to make information available to the citizens of countries where the government would prefer to withhold that information from the citizens. So in our view it's certainly not in the interest of the citizens of the countries where governments deny that information. We think it's in the long-term interest of the industry, of the investors, that countries be well governed, and transparency contributes to that.
Companies have said there's a cost issue. Companies have to keep books and records about their tax payments, so they have the information. We know it's a question of whether they're willing to disclose it. There certainly will be some cost in creating the software to meet the Securities and Exchange Commission's final determination of how that information should be reported. But in the view of the SEC and others that assess the cost, it's a one-off and not significant relative to the profitability and returns to these companies.
On the competitiveness argument that we're intruding on sovereignty, standard confidentiality clauses the governments and companies sign typically allow an out for regulatory home country requirements, so they're not violating contractual terms. The biggest fight recently has been over project by project. That's why we have suggested the SEC define a project that has a lease or concession, because that's the basis on which taxes, other payments, tax holidays, and cost recoveries are determined. Companies have to keep the books that way, so that's the lowest-cost option for requiring the disclosure.