Thank you, Mr. Chair.
For tax purposes, the determination of whether in a particular transaction the parties are dealing at arm's length is a factual decision that's made on the basis of the circumstances at issue. One of the criteria that might be looked at is whether the parties are related to one another, but there are others.
This amendment would have the wrong result, because it would deem persons who are unrelated to each other not to be dealing at arm's length. They may, however, in fact be acting in collusion to provide an inappropriate tax result, so we do not want to have a provision that would deem them to be dealing at arm's length.