I'm not a tax expert, but I know that during the negotiations, when there was close consultation with industry, provinces, and the government in terms of what the objectives were and what we were trying to do in the negotiations, the emphasis was on resolving the issue and bringing refunds back into Canada.
During the negotiations there was no discussion that I'm aware of about how the money would be taxed once you brought it back into Canada. That was not a focus of discussion, as far as I'm aware, during the negotiation of the SLA and bringing it into force.
I think how the Canadian tax system deals with that money coming back in is a question of a taxing approach, because all companies' fiscal positions would not be the same. Some companies would have a lot of elements against which they could debit the money coming back; the extent to which each country sees its own position with respect to the tax regime is also a condition of its own tax situation, so I think it would be difficult to determine whether it benefits companies or not. Clearly your perspective is valid, I would think, for some companies that would prefer to be able to go back in a number of years to identify that as a debit.
I think that type of issue and that ruling are in the context of Canadian tax law, not in the context of the softwood lumber agreement, and we've heard from CRA how the opinion has been given with respect to the taxing of that money.