Public Accounts committee  I think that's right.

Public Accounts committee  I'm from Finance. Maybe I'll take that one. RRSP strips are a good example of something on the border between evasion and avoidance. Some of the first-generation structures were so aggressive that CRA argued that, under existing rules in fact the tax plan was not effective and just not legal, and that would tip you over to an evasion category.

Finance committee  It sometimes happens that taxpayers do not agree with the position of the Canada Revenue Agency.

Finance committee  I just want to clarify the government's position on the effect. The CRA's position currently is that cable laying is not included in the concept of international shipping, and therefore amendments to add cable laying to the concept of international shipping would be an expansion.

Finance committee  Could I just add a couple of things from a policy perspective? The international shipping rules, as they exist, are quite long-standing and conform to international norms in relation to shipping. They do provide effectively an exemption from Canadian income tax on this activity.

Finance committee  The measure will eliminate a special exception for the tax treatment of offshore trusts for new Canadians who have been in Canada for less than 60 months. I could not say specifically whether that would affect particular immigrants under particular programs. Any new Canadian who brings their assets to Canada would not be affected by the measure.

Finance committee  If I understand correctly, it's: will the measure will have an impact on the program for immigrant investors?

Finance committee  Prior to these changes.

Finance committee  If I understand correctly, your question is: who pays the tax?

Finance committee  There are many categories of trusts in the tax rules, but fundamentally two large categories, testamentary trusts and and inter vivos trusts, so trusts created by will or estate, and all other types of trusts. Under the existing regime, essentially any trust created by a will qualified as a testamentary trust, so the tax planning that was being observed was taxpayers creating many testamentary trusts for one estate under the same will.

Finance committee  I'm sorry, but I seem to be having a little bit of trouble with the acoustics in this room. Did you ask for clarification on the—

Finance committee  Sure. There is an existing tax rule to assist farmers in situations where they're facing drought, flood or excess moisture conditions which force them to sell livestock, essentially because they can't feed the animals as a result of those conditions. The existing rule allows farmers in those circumstances to defer the income from the forced sale of the livestock until a subsequent taxation year when the expectation would be they would normally be replenishing the herd at that point and they'd have a match between their income from the sale and their expense in acquiring new animals.

Finance committee  The existing policy is to provide accelerated capital cost allowance, which is faster tax write-offs for renewable energy equipment and clean energy equipment. Budget 2014 expands the list of equipment that qualifies for that tax incentive to include certain other types of.... Kevin, sorry.

Finance committee  July 12, 2013 is the date that the proposals were first released for consultation, so in order for taxpayers to be aware of the new rules, that's the basic explanation for that proposed coming-into-force date.

Finance committee  Yes, the technical measures in the bill have all been released for comment previously. The largest component of them was released on July 12, 2013, as a consultation package.