Unless the phrase “"specifically provided” is changed, which certainly could be done, and unless, therefore, there was reliance not on the Financial Administration Act but on something internal to this legislation, then those who've received 82%, under the terms of the bill, would face an additional tax on the 100% of 20%. Where they gave up the 18% is not in the bill; they gave it up in the purchase and sale option. This gave the government authority to return it to them--less than 100%--and they gave it up in the irrevocable power of attorney, which authorized U.S. Customs authorities to turn the money over to the Government of Canada instead of to them.
So it's not in the bill; it's in those other two documents. By virtue of those transactions, the bill says they pay on all of the refund. All of the refund that in fact went to the Government of Canada is 100%, but they're getting 82% under the terms of the purchase and sale agreement that they signed with EDC.