Proceedings of the Standing Senate Committee on
Banking, Trade and Commerce
Issue 20 - Evidence
OTTAWA, Wednesday, October 24, 2001
The Standing Senate Committee on Banking, Trade and Commerce, to which was referred Bill S-31, to implement agreements, conventions and protocols concluded between Canada and Slovenia, Ecuador, Venezuela, Peru, Senegal, the Czech Republic, the Slovak Republic and Germany for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income met this day at 3:45 p.m. to give consideration to the bill.
Senator E. Leo Kolber (Chairman) in the Chair.
[English]
The Chairman: Good afternoon. Today we will discuss Bill S-31 an act to implement agreements, conventions and protocols concluded between Canada and Slovenia, Ecuador, Venezuela, Peru, Senegal, the Czech Republic, the Slovak Republic and Germany for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Appearing will be Mr. John McCallum, Member of Parliament and Parliamentary Secretary to the Minister of Finance, and from the Department of Finance, Mr. Brian Ernewein and Mr. David Senecal.
Mr. McCallum, please proceed.
[Translation]
Mr. John McCallum, M.P., Parliamentary Secretary to the Minister of Finance: Mr. Chairman, it is a pleasure and a privilege for me to appear before your committee for the first time since being elected to office. When I testified before you for the very first time, it was as an economist.
[English]
Mr. McCallum: To the best of my knowledge this matter involves eight tax treaty agreements: three are updates from previous ones with the Slovak Republic, the Czech Republic and Germany; and the rest are new with the countries of Slovenia, Ecuador, Venezuela, Peru and Senegal.
There are two purposes to having tax treaties. The first is to remove barriers to cross-border trade and investment, and this, of course, is particularly important for us because we are so exposed to foreign trade. The removal of that uncertainty with respect to tax has a major advantage for Canada's commercial success.
These agreements do a number of things: They allocate the right to tax between the two countries, and they also have undertakings to resolve disputes. Further the agreements encompass obligations to eliminate double taxation, pledges of non-discrimination and commitments to give advance notice of any desire to terminate the arrangement. The exclusion or elimination of double taxation is clearly one of the more important features of the agreements.
With respect to withholding tax, in the absence of tax treaties, these are formally set at 25 per cent, and under these treaties the withholding tax rates are lower. They are in the range of about 5 per cent to 15 per cent, depending on the agreement in question.
The second purpose is to ensure unintended consequences, which means, in less polite language, tax evasion. This is done in a number of ways. It allows the tax authorities to deal directly with each other to solve international transfer pricing issues. It allows them to mutually agree to satisfactory solutions involving concerns raised by taxation and taxpayers. The tax authorities are allowed complete audits and to engage in other discussions aimed at improving tax administration.
The last point is with respect specifically to the Canada-Germany agreement. This is the only one that provides for mutual assistance in the collection of outstanding taxes. We have such agreements with other major countries, including the United States and the Netherlands, but we tend not to have such agreements with smaller partners.
In summary, the advantages of these tax treaties are: a more simplified tax treaty system; a more stable environment for investors and traders; and the elimination of double taxation that would otherwise cause a great deal of trouble.
In the interests of brevity, that ends my comments.
[Translation]
Senator Meighen: As a former Montrealer like yourself, I welcome you to this committee. You now represent a Toronto area riding and I too reside in Toronto. Montrealers can be found just about anywhere in Canada. Congratulations on your appointment.
[English]
In a previous Senate committee hearing on these agreements, the question arose about the human rights record of one of the particular countries. Within the Department of Finance, is this a consideration prior to or during the negotiation of such treaties?
Mr. McCallum: My sense is that the Department of Finance does not make the judgments on the human rights conditions of the various countries. The Department of Foreign Affairs does that. It is not within our mandate to comment, but they have opined that, while certainly not perfect, they were adequate in terms of human rights to proceed with tax treaties.
Senator Meighen: Can I infer from that that if a country had, in the estimation of the Department of Foreign Affairs, a deplorable human rights record, they would ask the Department of Finance not to proceed with negotiation of such a treaty?
Mr. McCallum: I believe that is true.
Mr. Brian Ernewein, Director, Tax Legislation Division, Tax Policy Branch, Department of Finance: It is perhaps unfair to the Parliamentary Secretary to leap into this because some of discussion relates back to our previous round with the Senate committee on the previous tax treaty bill. The short answer to the question is that we seek the Department of Foreign Affairs' input on the question of whether to have tax treaty negotiations and to seek to enter into a tax treaty with another country, and their advice may be based on a range of factors, including the level of prospective investment activity and indeed on human rights. I do not recall that we have had a situation where the Department of Foreign Affairs had advised or recommended to us that we not enter into a tax treaty because of human rights concerns and that we went ahead and did it in any event.
Senator Meighen: Is the department aware of the negotiations that you are undertaking?
Mr. Ernewein: Most certainly.
Senator Meighen: Are they aware of the identity of the countries with which you are negotiating?
Mr. Ernewein: Certainly.
Senator Meighen: Obviously, these conventions do not take effect until they are ratified by both states. Is there a procedure? Do we go first or do they go first or how is that determined? Who ratifies the convention first?
Mr. Ernewein: Often it is a matter of happenstance. Within this treaty bill we have eight treaties.
Those are the treaties that were signed since the last income tax treaty implementation bill was put forward. In the course our parliamentary process it was, we hope, convenient to have introduced it in the fall session of this Parliament. The processes of some of the other countries will have been at different stages so if they follow a process much the same as ours, the treaty signed with Canada may have been their eighth treaty, signed a year after their last implementation legislation went forward. Therefore, it may have been ratified beforehand.
The short answer is that we may ratify ahead of them; they may ratify ahead of us sometimes. We obviously try to keep in touch to find out where the ratification processes are in both countries, in the other country as well as ours.
Senator Meighen: Mr. McCallum said that some of these are bringing up to date existing treaties. Is that so?
Mr. McCallum: There were three treaties in that category. I think the Slovak Republic treaty and the Czech Republic treaty have been redone to indicate that these are now two countries. In the case of Germany, there have been a few changes. The mutual assistance clause is new. The Germany treaty has been made better and the Slovak and Czech ones have been split into two entities.
[Translation]
Senator Poulin: Mr. McCallum, if my memory serves me correctly, the model was developed in 1966 by the OECD and the bill under consideration would implement agreements that have already been negotiated. Have the negotiations with all of the countries listed in this bill been concluded, and have the agreements been ratified by both states?
Mr. McCallum: All negotiations are patterned after the OECD model. We negotiate according to this general model, or prototype, with some variations in relation to the withholding tax rate, and so forth. These negotiations are still fairly new, but this standard model has been used extensively in the past.
[English]
Mr. Ernewein: I would like to add a couple of comments. The first is that we do follow a general model. It is basically the Organization of Economic Cooperation and Development model tax treaty with some variations in relation to withholding tax rates, et cetera. All the negotiations are patterned after a model.
The second point is that this is an agreement that the Government of Canada has already signed. Therefore, if it had to be changed, we would have to seek a different agreement with the other country. We could not change it on our own.
The agreements do not take effect until approved by Parliament. That is the reason for the implementation bill and the reason we are here today.
Senator Poulin: Is the process the same in every other country? In other words, do they also have to have the agreements ratified by their Parliament before the agreements come into effect?
Mr. Ernewein: They are often very much alike, but not always. The best example I can give is the one with which I am the most familiar. It does not concern a treaty on the list today. I know that in the United States signature of a tax treaty or other treaties by the executive branch requires ratification of a sort, which involves not approval of both houses of Congress but rather approval by the Senate foreign relations committee followed by a vote of the Senate itself. There are differences in process although largely they follow the process of signature and some ratification procedure.
Senator Fitzpatrick: Mr. McCallum, or perhaps you wish to refer this to your officials, and it does not have to do specifically with the new participants to this treaty. I have heard your comments in respect to double taxation and withholding taxes. Could you advise me of the current arrangement for actors and athletes between Canada and the United States? What are the tax arrangements?
It was an issue a year or so ago with respect to actors coming to Canada and participating in filmmaking. There was a move to have them file taxes in both Canada as well as the United States. We have a $1 billion movie industry in the Province of British Columbia, and I believe this is an issue that is coming up again. That requirement is certainly very detrimental to the industry. With all the other impediments we seem to have with respect to trade, I wonder if you could tell me the current status and if there is some consideration with respect to providing relief so that we can continue to enjoy the kind of movie making activity that we have had in British Columbia over the last several years?
Mr. McCallum: That is a good question. It is also a question I will refer to the officials.
Mr. Ernewein: The answer in relation to the taxation of foreign actors performing services in Canada is not affected by any of the tax treaties before you. It is strictly a question of the level of Canadian tax imposed on this non-resident group of individuals.
With respect to what has been done with the group of non-resident actors, I will give you a bit of history. Non-resident actors have, like other non-residents performing services in Canada, been liable to the same tax rules that apply to the other group. That is, their income from Canadian sources is subject to Canadian tax. The practice, however, has been that such actors would be subject to the withholding tax arrangements under the Canadian tax system with a 15 per cent rate of tax applying to them. They were generally not required to follow up with individual tax returns, and are thus not required to pay whatever level of taxes that might involve.
That was a somewhat unsatisfactory approach because although the practice may have had some appeal, it was not considered to be necessarily in accordance with the strict letter of the law. We looked at what we could do to improve that situation without creating a concern with the level of taxation imposed on this non-resident group that might have a deleterious effect on the Canadian film industry.
After more than a year of consultations between the revenue agencies, the Department of Finance, the groups affected and the representatives of the film industry, an arrangement was reached. That was announced late last year. It set a tax rate applying specifically to non-resident actors performing services in Canada. Under that arrangement the withholding tax rate was increased from 15 per cent to 23 per cent. By way of explanation, the 23 per cent rate was arrived at as a reasonable estimation of the effective tax rates this group, particularly U.S. actors performing services in Canada, might pay on a net basis on their income in the U.S. Therefore, by imposing a 23 per cent tax rate in Canada, we were not exacting more from the group than they would be paying on that income in the United States nor would we be simply transferring tax revenue to the U.S. treasury as would have been the case if we had set the rate lower because the effects would have just been taxed away by the U.S.
The Chairman: Do they get a credit when they go back?
Mr. Ernewein: Yes, at least federally. There are some state tax issues, but certainly federally and in most of the states credit for the Canadians tax would be provided. In point of fact, I think that U.S. federal credit is all that matters because the rate of the Canadian tax will all be within the U.S. federal tax room for credit purposes.
We have anticipated and dealt with the problem of the tax rate that we have established. That seems to be confirmed with the experience of the past eight to ten months.
Senator Fitzpatrick: It is your understanding that will be a status quo and that there will be no change to that because there is nothing new being contemplated by either revenue or finance in that respect.
Mr. Ernewein: That is right. We believe the system is working. The 23 per cent rate was legislated in June, 2001. As I say, we think it is functioning properly.
The Chairman: In your briefing notes, it states:
As a general rule, exclusive jurisdiction is conferred either on the State where the taxpayer resides or on the State where the income arises. Income from real property and immov ables, business profits, the income earned by performers and athletes, and payment received as a salaried employee, are taxable only in the State where the income arises.
That is slightly misleading if you are giving them a better rate than a Canadian would get in the same situation.
Mr. Ernewein: I am afraid you have us at a disadvantage because we are not sure which briefing note you are referring to.
The Chairman: The notes from the Library of Parliament.
Mr. Ernewein: That makes it easier for us to be critical of it.
The Chairman: I will give this to you. There is no sense belabouring it now. Drop me a note and tell me if it is accurate.
Mr. Ernewein: I can tell you quickly that there are three possible ways for income taxation to be divided. The tax could be exclusively given to the source country, which is rare. More commonly, the taxation authority exclusively rests with the residence country. The most common method is that the tax authorities are shared between the two countries. The source country will collect on employment income, at least a longer-term employment income and on business profits, where the business is carried on in connection with a permanent establishment or fixed base. The source country will have the right to tax the country of the taxpayer's residence, or, the other country will have an obligation to provide credit for the source country's tax. We are happy to follow up on that for you.
The Chairman: If President Clinton is coming to Montreal to give a speech and receives $100,000 as his fee, where is he taxed?
Mr. Ernewein: I will have to get your view as to whether you think President Clinton is an actor or not.
The Chairman: I quit.
Mr. Ernewein: Assuming he is not, the taxation would be only in the state of residence in the U.S.
The Chairman: Even though he earns it here?
Mr. Ernewein: That is right. In most cases, except for artists and athletes, short-term personal services are taxable only in the resident's country.
Senator Fitzpatrick: I appreciate the answer you gave me and I heard what you said. You mentioned that there are varying tax rates set by the different states. Can you clarify if this arrangement is agreeable to the state of California or does that provide a problem to those actors? It seems to me that it was an issue with the State of California.
Mr. Ernewein: I think you are right. There has been an issue with the State of California and whether they were prepared to give credit for the Canadian tax payable by actors on their income generated from providing services in Canada. However, the system we have instituted does not depend upon resolution of that issue. That is to say, the rate we have said is a rate that can be credited without requirement of agreement by California.
Senator Kroft: I would like to pick up on a reference you made in your note concerning the pending agreement with Germany and having to do with mutual assistance. You said that was better.
I seem to remember, as a matter of common law principle, that countries would not enforce one another's taxing statutes. What has evolved? I am going back nearly 40 years, but what has been the evolution of assisting other countries? Is that assistance in terms of the investigation, of the gathering of information, or of the action in our courts? Can you give me an idea of how this mutual assistance works?
Mr. Ernewein: Your question extends beyond assistance in collection because it also relates to the exchange of information provisions, which have been part of our treaties for many years. You are right that there is a general prohibition under international law of one country enforcing another country's taxes. That is premised on the view of sovereignty. That is the reason for the assistance and collection Article 2 to create, in limited circumstances, an exception to that general outcome.
The assistance we provide in enforcement and the like, that arises generally through the Exchange of Information Article. If one country considers that it has need of some information that the other country may possess with respect to its own taxpayers having investments in the first country, or vice versa, it may ask the country for information to try to enable it to make its own assessment of the tax owing by the taxpayer. That is what the exchange of information provisions does.
The second piece of that deals with a situation where a country determines, to its own satisfaction, that a tax liability arises and further, that any dispute or appeal of that assessment has been proceeded with and the taxpayer has exhausted all rights to challenge that assessment. Then what can that country can do in terms of enforcement of what is now a tax debt in respect of that other country or assets located in other country? Generally, again, there is no enforcement of tax debts of one country in another. The Assistance in Collection Article proposes the allowing, in limited circumstances, one country, for example, Germany, to request of another country, say, Canada, that it seek to enforce the German tax debt as though it were an amount of Canadian tax owing.
Once again, it is not a matter of verifying the debt, but rather it is a matter of determining that the German tax debt is final and due; and that the level of assistance provided by Canada is required to be commensurate with the amount of assistance we get from Germany as well, in terms of their collection of tax debts on our part.
Senator Kroft: Most Canadians operate with the understanding that information in their tax returns is for the purpose of the Canada Customs and Revenue Agency and that the information is not available to other agencies. I have not checked the current pending legislation to see whether there are circumstances that breach that.
In respect of the nature of information that would be shared, would it be as if this were an extension of the agency? Would it be as if it were another branch of government seeking information? I wonder what degree of confidentiality is shared between governments in this process?
Mr. Ernewein: Once again, I will separate the answers into two things: exchange of information and assistance in collection. I will deal with the latter first, because it is easier. The assistance in collection involves no exchange of information at all. The example of Germany and Canada provides an example of the only information exchanged: if Germany has an amount that it has determined to be owing to it in respect of taxes for which the taxpayer or the taxpayer's assets are situated in Canada, the only information exchanged is the actual amount of the tax debt. They would ask Canada to assist them in the collection of that debt.
The prior question is what information might we ask of Germany, if the situation were reversed, in an attempt to assess taxes owing by a Canadian taxpayer? The taxpayer is thought to have investments in Germany that are producing income, and we are seeking information from Germany to verify that.
In that circumstance, the information we request of Germany can only be used by us in the administration and enforcement of our taxes and not for another purpose. That is a part of our existing exchange of information agreement with Germany and with most other countries. It is not altered by the assistance and collections provision.
Senator Hervieux-Payette: I have three quick questions. I notice that you have 72 conventions that are now in force. There are some signed and not in force yet and some that are being negotiated. What is the process for negotiation? Who has the final authority, is it finance or foreign affairs? As far as I know it is not a large team. Out of nearly 200 countries why are we so low in terms of these conventions? For Canadian business people this convention is certainly an advantage. It makes me wonder. What prevents us from moving a little faster on this? Why are we jammed with so many?
Mr. McCallum: This figure may seem to low, but it is more than most other countries in the world. Perhaps the officials have better information.
Mr. David Senecal, Tax Policy Officer, Tax Treaties Section, Tax Legislation Division, Tax Policy Branch, Department of Finance: The problem you refer to is not a problem unique to Canada. Most other countries are in the same position as we are. Often we are ready to proceed and they are not. They have resource problems as well.
You mentioned the situation with Australia. It has taken time because of the shortage of their resources and because of their other priorities. They went through a major tax reform, and negotiators were reallocated to that assignment. The delays with respect to that particular country were not our fault or because of our lack of resources. As a matter of interest, those negotiations are now complete.
Senator Hervieux-Payette: Does the complete responsibility rest with finance? Does it have nothing to do with foreign affairs? Do foreign affairs people intervene, follow or accept? What is the mechanism of the process? Which department has the last word in putting these conventions in place? Is it always the Department of Finance?
Mr. Ernewein: The recommendation to sign a treaty is a joint recommendation of the Minister of Finance and the Minister of Foreign Affairs. In terms of the content of the tax treaty which is the mandate of the Minister of Finance, it is presumably not surprising to learn that most of the content of the treaty is determined by the Minister of Finance, in consultation with, and on the advice of, representatives of Canada Customs and Revenue Agency, who participate in the discussions.
Participation by foreign affairs in the discussions does happen, but not always. They are involved at the beginning of the day in terms of whether to launch discussions, and at the end of the day in terms of whether to recommend approval of the treaty.
Senator Hervieux-Payette: I have followed more carefully the convention with Germany. It took quite some time to go through, and now, are we revisiting the same convention that was supposed to be approved earlier this year? That took four or five years to take place.
Mr. Ernewein: For better or for worse, the process often seems to involve years rather than months. There are exceptions where we are able to reach agreement on the first rounds of the discussions and through fortunate timing. Sometimes a treaty may be implemented within a year of even the first thought of entering into discussions. Generally, though, it does take long. It seems to be the nature of international relations.
Also, the sheer number of treaties is not necessarily the goal. I am not sure we want to have 200 tax treaties. There are countries that do not have tax systems, and so it would not be any advantage for us to negotiate a tax treaty with them. While it is not proof that a lower number is better than a higher one, I cite, as an example, the United States has fewer tax treaties place than we have.
There are different approaches to determining the right number of tax treaties and with which countries you want to have those tax treaties.
Senator Hervieux-Payette: You mentioned that the state or the provinces negotiate but, certainly, not on behalf of the provinces. What is happening in relation to taxes in our provinces or the Länders in Germany? We just solved the problem at the federal level. Do the provinces have to go ahead and negotiate by themselves?
Mr. Ernewein: I cannot speak for the federal systems in other countries. In terms of our own system, you are absolutely right to point out that we can only bind the federal level in respect of the tax treaties that we enter into. That does not mean the provinces follow up with their own tax treaties on the same score. Often, the kinds of items we are negotiating are exclusively federal taxes. That is a matter within our exclusive jurisdiction.
The provinces follow the tax treaties in almost every respect. The practical answer is that, while we certainly tell our treaty partners, or would-be treaty partners, we cannot bind the provinces, we also say that as a practical matter, the treaty is followed at both the federal and provincial levels.
Senator Meighen: I do not have the documentation with me to give you any details, but an acquaintance of mine, who is a German citizen resident in Ontario, is setting up real estate trusts designed to attract German money. He tells me that he finds himself at a disadvantage vis-à-vis people in the United States who are trying to attract the same money to be invested in that country.
That is generally what I have been told. When you are negotiating a treaty with another country, does anyone look at it in consideration of where it places us vis-à-vis our largest trading partner, the United States, and whether after this treaty is concluded, we would be at an advantage when dealing with the Republic of Germany or at a disadvantage with the Americans?
Mr. Ernewein: Yes, we seek to, both in terms of our treaty negotiations and indeed in terms of domestic tax policy. We would have to identify that information ourselves, but another route to obtain assistance in that respect is to make announcements of all upcoming treaty negotiations. For instance, in the case of renegotiation of the Canada-Germany treaty, people would have an opportunity to identify these sorts of concerns and it would give us an opportunity to consider the appropriateness of making such a change.
Senator Meighen: When and how is this announcement made?
Mr. Senecal: As soon as an agreement has been reached with another country, we undertake these negotiations. Our minister issues a press release announcing negotiations and inviting the public to make any submission they wish in respect to any problems that may be having, whether with an existing treaty, if we are renegotiating, or in the absence of a treaty. We take all of these things into account.
Senator Meighen: You have no sense of how long it takes to conclude these negotiations? How long ago would that announcement have been made?
Mr. Senecal: Perhaps it was made three or four years ago. However, the private sector and their advisors have an interest in having problems followed in the negotiations quite closely. I receive phone calls on an hourly basis about where we stand with countries such as Germany. We keep them pretty well up to date with information and, to the extent possible, with the areas where there are disputes. We had problems and delays with the Canada-Germany treaty and so we tried to make some of the effects retroactive to January 1, 2001.
Senator Hervieux-Payette: In Germany, the Länders have a say and so they participate in the process. That is why it took four years. In Canada, the federal government does the negotiating, so we do not have to coordinate other partners and seek their support. There are more than 10 Länders in Germany, so it took a long time to negotiate.
Senator Meighen: Do they have more than 10?
Senator Hervieux-Payette: Yes, there are 26 or 30 Landers.
Senator Callbeck: I want to go back to something that was brought up a few minutes ago. The former President of the United States, Mr. Clinton, gave a speech and received 100,000 for doing so. The income tax he pays on that is in the States. Can the company that invited him here to speak for a corporate event write off the $100,000 expense in Canada?
Mr. Ernewein: If the company you are speaking of is a Canadian company that is conducting this as a for-profit venture then we would tax the profit that is the difference between what they brought in. However, in terms of what they had to pay the speaker, former President Clinton in this example, I am not aware of a reason why that would not be a deductible expense.
Senator Callbeck: In other words, people from the United States come into Canada, work for a Canadian corporation on a short-term basis and pay their income tax to the states.
Mr. Ernewein: In that example, yes.
Senator Callbeck: And the Canadian company writes it off.
Mr. Ernewein: It is the same as the cost of buying goods from the U.S. or other foreign persons would be a deductible expense to the person buying the goods here and it would only be included in the income of the foreign taxpayer. That is correct.
Senator Fitzpatrick: For the interest of the committee, Mr. Chairman, President Clinton is speaking in Vancouver on November 9 if anyone wants to go. I think the tickets start at $5,000.
The Chairman: It is much cheaper in Montreal, and it is for a charity.
Senators, is it agreed that we do a clause-by-clause consideration of Bill S-31?
Hon. Senators: Agreed.
The Chairman: Bill S-31, an act to implement agreements, conventions and protocols concluded between Canada and Slovenia, Ecuador, Venezuela, Peru, Senegal, the Czech Republic, the Slovak Republic and Germany for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Is it the intention of any honourable senator to propose an amendment?
Shall the title stand postponed?
Hon. Senators: Agreed.
The Chairman: Shall clause one, the short title, stand postponed?
Hon. Senators: Agreed.
The Chairman: Shall Part 1, clauses 2 to 7 carry?
Hon. Senators: Agreed.
The Chairman: Shall Part 2, clauses 8 to 13 carry?
Hon. Senators: Agreed.
The Chairman: Shall Part 3, clauses 14 to 19 carry?
Hon. Senators: Agreed.
The Chairman: Shall Part 4, clauses 20 to 25 carry?
Hon. Senators: Agreed.
The Chairman: Shall Part 5, clauses 26 to 31 carry?
Hon. Senators: Agreed.
The Chairman: Shall Part 6, clauses 32 to 37 carry?
Hon. Senators: Agreed.
The Chairman: Shall Part 7, clauses 38 to 43 carry?
Hon. Senators: Agreed.
The Chairman: Shall Part 8, clauses 44 to 47 carry?
Hon. Senators: Agreed.
The Chairman: Shall schedules 1 to 8 carry?
Hon. Senators: Agreed.
The Chairman: Shall clause 1, the short title, carry?
Hon. Senators: Agreed.
The Chairman: Shall the title carry?
Hon. Senators: Agreed.
The Chairman: Shall the bill carry?
Hon. Senators: Agreed.
The Chairman: Shall I report the bill?
Hon. Senators: Agreed.
The Chairman: Again, thank you to the witnesses.
The committee adjourned.