Actually, that's our question, not the finance department's.
Starting in about 2000, after discussions with industry and practitioners, we put in place a cost-recovery process for advance income tax rulings. Those rulings, as you say quite correctly—around 200 to 225 a year—are binding on the agency. When we provide a ruling, on the assumption that all of the facts are correct and there's full disclosure, of course they are binding on the agency, which is why we take such care with them.
Ordinarily, the 99.9% of taxpayers who request information get that information through a non-cost process: through letters, pamphlets, bulletins, and brochures. That's how the vast majority of guidance is given and questions are answered. This process was set up specifically, as you can well imagine, for what I would call the really high-end, complex need for certainty—mostly, frankly, business types of transactions, at their request. I think there were even some observations in the Auditor General's report about the value of the rulings process, mostly to business.
So that happens on that side. And yes, when we provide something in writing on the assumption that the facts are correct, it is binding on the agency and the government, and we respect it. That is the case here.