That is helpful. It's been over two months since Minister Emerson said that companies absolutely had to have irrevocable letters of approval in to the government. Two months later, no company has actually completed the legal process. It's important for our committee to know that after more than two months none of the loose ends have been tied up. That helps us to plan our work and to make sure we're doing the due diligence on this bill. I appreciate your mentioning that.
I'd now like to come back to clause 18. We established on Tuesday that clause 18 imposes a charge on companies that they would quite possibly have to pay before getting any money back. I would like to refer specifically to subclause 18(6):
(6) If, at any time after September 18, 2006, a specified person sells or otherwise disposes of the rights to a duty deposit refund to a person other than Her Majesty in right of Canada, the specified person and the other person are jointly and severally, or solidarily, liable to pay the charge under subsection (3) and any penalties and interest payable under this Act in relation to that charge.
What we have here in clause 18, then, is not only the imposition of a special charge but also potential penalties and interest payable under the act.
It's possible that this charge could be miscalculated. What is the appeal process for companies? If the government botches the calculation of the charge in relation to a company—and there are strong punitive measures—what appeal process does the company use to dispute the charge?