In my view, treaty shopping is a serious problem. The gains that went untaxed as a result of the two treaty shopping cases that have gone to the courts are almost a billion dollars. That's a lot of money to use for other things.
I think the difficulty is that the government needs to take some specific action to deal with treaty shopping. It cannot rely on the GAAR as a result of the Supreme Court's decision, and it cannot rely on the new rules that have been added to Canada's tax treaties, because the result is going to be the same. And—