Finance committee  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.

Finance committee  Thank you, Mr. Chair. Happy Valentine's Day, everyone, although what I have to talk about, tax avoidance and the general anti-avoidance rule, have very little to do with love and romance. At the outset I would like to emphasize that I am appearing here on my own behalf. I have no special interest that I represent, and as a result I'd like to share with you a little bit about my background and experience with respect to tax.