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Finance committee  The 10% refundable income trust tax proposal is basically the status quo, except as it applies to Americans. It requires that new business taxes be collected from the American owners. All current deferred tax accounts and taxable accounts will pay 10% but will get it refunded, so

May 29th, 2007Committee meeting

Dianne Urquhart

Finance committee  I'm not sure I understood. Is this the issue of needing a lower cost of capital in order to exploit the energy assets in the western basin?

May 29th, 2007Committee meeting

Dianne Urquhart

Finance committee  My feeling is that if oil is at $64, up from $25 just a short two to three years ago, and we need to have a Canadian government subsidy in order to create a lower cost of capital.... When I say it was overvalued, the flip side of that is a lower cost of capital; if you have a hig

May 29th, 2007Committee meeting

Dianne Urquhart

Finance committee  The difference is the nature of the buyer. We're talking about a product that was said to be designed for seniors whose objectives were preservation of capital and income for the purpose of meeting their household expenses.

May 29th, 2007Committee meeting

Dianne Urquhart

Finance committee  No. Already, in a strong economic period with no new taxes needing to be paid, close to one-third of the business income trusts have suspended or massively slashed their distribution. That has nothing to do with income trust tax. They had to slash because they were set too high.

May 29th, 2007Committee meeting

Dianne Urquhart

Finance committee  The business income trusts and the energy trusts were about 50% overvalued prior to the announcement. I've estimated that taxes are about 10%, so the promise not to take a tax would have kept them 10% above where they should have been--but there was another 40% overvalue, in my o

May 29th, 2007Committee meeting

Dianne Urquhart

Finance committee  I'm not experienced enough or expert enough to make a comment in the area of application of GAAR to double dipping, but in the case of the interest deductibility for third-party debt raised to fund foreign acquisitions, the GAAR and the thin cap rules apply to non-arm's-length de

May 29th, 2007Committee meeting

Dianne Urquhart

Finance committee  I think we had a few acquisitions prior. I think that if the master limited partnerships are entitled to come here and buy income trusts and not pay business taxes as a result of the belief of a tax advisor such as James, who is sitting next to me, that they're not going to be ab

May 29th, 2007Committee meeting

Dianne Urquhart

Finance committee  I don't know that factually, but I believe the average annual for the prior three years was approximately 20%, so I'm going to guess it's 10%. It would have been a substantial return because there had been such a flow of billions of dollars of the retail market into the income tr

May 29th, 2007Committee meeting

Dianne Urquhart

Finance committee  I think the average annual for the prior three years was approximately 20%, so they had become overvalued.

May 29th, 2007Committee meeting

Dianne Urquhart

Finance committee  But if you bought them just prior and you sold them just after, you had a loss. I would like to note that our call for a criminal investigation was made because there are 50 names that are down 20%. Someone who was not properly diversified or who unfortunately had a high propor

May 29th, 2007Committee meeting

Dianne Urquhart

Finance committee  Well, first of all, apply GAAR and apply the thin capitalization rules. I'd like to note that in the United States the IRS did apply its anti-avoidance rules against the Canadian income trusts that owned American businesses, so we don't have to be worried about needing to have re

May 29th, 2007Committee meeting

Dianne Urquhart

Finance committee  First of all, section 245 of the Income Tax Act is the general anti-avoidance rule. If you make an attempted avoidance transaction that is for the purpose of only getting a tax benefit, and if it's determined that the transaction is abusive, then the Canada Revenue Agency is able

May 29th, 2007Committee meeting

Dianne Urquhart

Finance committee  No, I do not agree. First of all, just to review income trusts, the way in which no business taxes were paid was primarily through each of the income trusts, which is itself a legal structure, having a corporate subsidiary. In the corporate subsidiary, that is where you have vi

May 29th, 2007Committee meeting

Dianne Urquhart

Finance committee  No, I have to answer the question. Do I have time?

May 29th, 2007Committee meeting

Dianne Urquhart