Bill C-45 (Historical)

Jobs and Growth Act, 2012

A second Act to implement certain provisions of the budget tabled in Parliament on March 29, 2012 and other measures

Part 1 implements certain income tax measures and related measures proposed in the March 29, 2012 budget. Most notably, it
(a) amends the rules relating to Registered Disability Savings Plans (RDSPs) by
(i) replacing the 10-year repayment rule applying to withdrawals with a proportional repayment rule,
(ii) allowing investment income earned in a Registered Education Savings Plan (RESP) to be transferred on a tax-free basis to the RESP beneficiary’s RDSP,
(iii) extending the period that RDSPs of beneficiaries who cease to qualify for the Disability Tax Credit may remain open in certain circumstances,
(iv) amending the rules relating to maximum and minimum withdrawals, and
(v) amending certain RDSP administrative rules;
(b) includes an employer’s contributions to a group sickness or accident insurance plan in an employee’s income in certain circumstances;
(c) amends the rules applicable to retirement compensation arrangements;
(d) amends the rules applicable to Employees Profit Sharing Plans;
(e) expands the eligibility for the accelerated capital cost allowance for clean energy generation equipment to include a broader range of bioenergy equipment;
(f) phases out the Corporate Mineral Exploration and Development Tax Credit;
(g) phases out the Atlantic Investment Tax Credit for activities related to the oil and gas and mining sectors;
(h) provides that qualified property for the purposes of the Atlantic Investment Tax Credit will include certain electricity generation equipment and clean energy generation equipment used primarily in an eligible activity;
(i) amends the Scientific Research and Experimental Development (SR&ED) investment tax credit by
(i) reducing the general SR&ED investment tax credit rate from 20% to 15%,
(ii) reducing the prescribed proxy amount, which taxpayers use to claim SR&ED overhead expenditures, from 65% to 55% of the salaries and wages of employees who are engaged in SR&ED activities,
(iii) removing the profit element from arm’s length third-party contracts for the purpose of the calculation of SR&ED tax credits, and
(iv) removing capital from the base of eligible expenditures for the purpose of the calculation of SR&ED tax incentives;
(j) introduces rules to prevent the avoidance of corporate income tax through the use of partnerships to convert income gains into capital gains;
(k) clarifies that transfer pricing secondary adjustments are treated as dividends for the purposes of withholding tax imposed under Part XIII of the Income Tax Act;
(l) amends the thin capitalization rules by
(i) reducing the debt-to-equity ratio from 2:1 to 1.5:1,
(ii) extending the scope of the thin capitalization rules to debts of partnerships of which a Canadian-resident corporation is a member,
(iii) treating disallowed interest expense under the thin capitalization rules as dividends for the purposes of withholding tax imposed under Part XIII of the Income Tax Act, and
(iv) preventing double taxation in certain circumstances when a Canadian resident corporation borrows money from its controlled foreign affiliate;
(m) imposes, in certain circumstances, withholding tax under Part XIII of the Income Tax Act when a foreign-based multinational corporation transfers a foreign affiliate to its Canadian subsidiary, while preserving the ability of the Canadian subsidiary to undertake expansion of its Canadian business; and
(n) phases out the Overseas Employment Tax Credit.
Part 1 also implements other selected income tax measures. Most notably, it introduces tax rules to accommodate Pooled Registered Pension Plans and provides that income received from a retirement compensation arrangement is eligible for pension income splitting in certain circumstances.
Part 2 amends the Excise Tax Act and the Jobs and Economic Growth Act to implement rules applicable to the financial services sector in respect of the goods and services tax and harmonized sales tax (GST/HST). They include rules that allow certain financial institutions to obtain pre-approval from the Minister of National Revenue of methods used to determine their liability in respect of the provincial component of the HST, that require certain financial institutions to have fiscal years that are calendar years, that require group registration of financial institutions in certain cases and that provide for changes to a rebate of the provincial component of the HST to certain financial institutions that render services to clients that are outside the HST provinces. This Part also confirms the authority under which certain GST/HST regulations relating to financial institutions are made.
Part 3 amends the Federal-Provincial Fiscal Arrangements Act to provide the legislative authority to share with provinces and territories taxes in respect of specified investment flow-through (SIFT) entities — trusts or partnerships — under section 122.1 and Part IX.1 of the Income Tax Act, consistent with the federal government’s proposal on the introduction of those taxes. It also provides the legislative authority to share with provinces and territories the tax on excess EPSP amounts imposed under Part XI.4 of the Income Tax Act, consistent with the measures proposed in the March 29, 2012 budget. It also allows the Minister of Finance to request from the Minister of National Revenue information that is necessary for the administration of the sharing of taxes with the provinces and territories.
Part 4 enacts and amends several Acts in order to implement various measures.
Division 1 of Part 4 amends the Trust and Loan Companies Act, the Bank Act, the Insurance Companies Act and the Jobs and Economic Growth Act as a result of amendments introduced in the Jobs, Growth and Long-term Prosperity Act to allow certain public sector investment pools to directly invest in a federally regulated financial institution.
Division 2 of Part 4 amends the Canada Shipping Act, 2001 to permit the incorporation by reference into regulations of all Canadian modifications to an international convention or industry standard that are also incorporated by reference into the regulations, by means of a mechanism similar to that used by many other maritime nations. It also provides for third parties acting on the Minister of Transport’s behalf to set fees for certain services that they provide in accordance with an agreement with that Minister.
Division 3 of Part 4 amends the Canada Deposit Insurance Corporation Act to, among other things, provide for a limited, automatic stay in respect of certain eligible financial contracts when a bridge institution is established. It also amends the Payment Clearing and Settlement Act to facilitate central clearing of standardized over-the-counter derivatives.
Division 4 of Part 4 amends the Fisheries Act to amend the prohibition against obstructing the passage of fish and to provide that certain amounts are to be paid into the Environmental Damages Fund. It also amends the Jobs, Growth and Long-term Prosperity Act to amend the definition of Aboriginal fishery and another prohibition relating to the passage of fish. Finally, it provides transitional provisions relating to authorizations issued under the Fisheries Act before certain amendments to that Act come into force.
Division 5 of Part 4 enacts the Bridge To Strengthen Trade Act, which excludes the application of certain Acts to the construction of a bridge that spans the Detroit River and other works and to their initial operator. That Act also establishes ancillary measures. It also amends the International Bridges and Tunnels Act.
Division 6 of Part 4 amends Schedule I to the Bretton Woods and Related Agreements Act to reflect changes made to the Articles of Agreement of the International Monetary Fund as a result of the 2010 Quota and Governance Reforms. The amendments pertain to the rules and regulations of the Fund’s Executive Board and complete the updating of that Act to reflect those reforms.
Division 7 of Part 4 amends the Canada Pension Plan to implement the results of the 2010-12 triennial review, most notably, to clarify that contributions for certain benefits must be made during the contributory period, to clarify how certain deductions are to be determined for the purpose of calculating average monthly pensionable earnings, to determine the minimum qualifying period for certain late applicants for a disability pension and to enhance the authority of the Review Tribunal and the Pension Appeals Board. It also amends the Department of Human Resources and Skills Development Act to enhance the authority of the Social Security Tribunal.
Division 8 of Part 4 amends the Indian Act to modify the voting and approval procedures in relation to proposed land designations.
Division 9 of Part 4 amends the Judges Act to implement the Government of Canada’s response to the report of the fourth Judicial Compensation and Benefits Commission regarding salary and benefits for federally appointed judges. It also amends that Act to shorten the period in which the Government of Canada must respond to a report of the Commission.
Division 10 of Part 4 amends the Canada Labour Code to
(a) simplify the calculation of holiday pay;
(b) set out the timelines for making certain complaints under Part III of that Act and the circumstances in which an inspector may suspend or reject such complaints;
(c) set limits on the period that may be covered by payment orders; and
(d) provide for a review mechanism for payment orders and notices of unfounded complaint.
Division 11 of Part 4 amends the Merchant Seamen Compensation Act to transfer the powers and duties of the Merchant Seamen Compensation Board to the Minister of Labour and to repeal provisions that are related to the Board. It also makes consequential amendments to other Acts.
Division 12 of Part 4 amends the Customs Act to strengthen and streamline procedures related to arrivals in Canada, to clarify the obligations of owners or operators of international transport installations to maintain port of entry facilities and to allow the Minister of Public Safety and Emergency Preparedness to require prescribed information about any person who is or is expected to be on board a conveyance.
Division 13 of Part 4 amends the Hazardous Materials Information Review Act to transfer the powers and functions of the Hazardous Materials Information Review Commission to the Minister of Health and to repeal provisions of that Act that are related to the Commission. It also makes consequential amendments to other Acts.
Division 14 of Part 4 amends the Agreement on Internal Trade Implementation Act to reflect changes made to Chapter 17 of the Agreement on Internal Trade. It provides primarily for the enforceability of orders to pay tariff costs and monetary penalties made under Chapter 17. It also repeals subsection 28(3) of the Crown Liability and Proceedings Act.
Division 15 of Part 4 amends the Employment Insurance Act to provide a temporary measure to refund a portion of employer premiums for small businesses. An employer whose premiums were $10,000 or less in 2011 will be refunded the increase in 2012 premiums over those paid in 2011, to a maximum of $1,000.
Division 16 of Part 4 amends the Immigration and Refugee Protection Act to provide for an electronic travel authorization and to provide that the User Fees Act does not apply to a fee for the provision of services in relation to an application for an electronic travel authorization.
Division 17 of Part 4 amends the Canada Mortgage and Housing Corporation Act to remove the age limit for persons from outside the federal public administration being appointed or continuing as President or as a director of the Corporation.
Division 18 of Part 4 amends the Navigable Waters Protection Act to limit that Act’s application to works in certain navigable waters that are set out in its schedule. It also amends that Act so that it can be deemed to apply to certain works in other navigable waters, with the approval of the Minister of Transport. In particular, it amends that Act to provide for an assessment process for certain works and to provide that works that are assessed as likely to substantially interfere with navigation require the Minister’s approval. It also amends that Act to provide for administrative monetary penalties and additional offences. Finally, it makes consequential and related amendments to other Acts.
Division 19 of Part 4 amends the Canada Grain Act to
(a) combine terminal elevators and transfer elevators into a single class of elevators called terminal elevators;
(b) replace the requirement that the operator of a licensed terminal elevator receiving grain cause that grain to be officially weighed and officially inspected by a requirement that the operator either weigh and inspect that grain or cause that grain to be weighed and inspected by a third party;
(c) provide for recourse if an operator does not weigh or inspect the grain, or cause it to be weighed or inspected;
(d) repeal the grain appeal tribunals;
(e) repeal the requirement for weigh-overs; and
(f) provide the Canadian Grain Commission with the power to make regulations or orders with respect to weighing and inspecting grain and the security that is to be obtained and maintained by licensees.
It also amends An Act to amend the Canada Grain Act and the Agriculture and Agri-Food Administrative Monetary Penalties Act and to Repeal the Grain Futures Act as well as other Acts, and includes transitional provisions.
Division 20 of Part 4 amends the International Interests in Mobile Equipment (aircraft equipment) Act and other Acts to modify the manner in which certain international obligations are implemented.
Division 21 of Part 4 makes technical amendments to the Canadian Environmental Assessment Act, 2012 and amends one of its transitional provisions to make that Act applicable to designated projects, as defined in that Act, for which an environmental assessment would have been required under the former Act.
Division 22 of Part 4 provides for the temporary suspension of the Canada Employment Insurance Financing Board Act and the dissolution of the Canada Employment Insurance Financing Board. Consequently, it enacts an interim Employment Insurance premium rate-setting regime under the Employment Insurance Act and makes amendments to the Canada Employment Insurance Financing Board Act, the Department of Human Resources and Skills Development Act, the Jobs, Growth and Long-term Prosperity Act and Schedule III to the Financial Administration Act.
Division 23 of Part 4 amends the Canadian Forces Superannuation Act, the Public Service Superannuation Act and the Royal Canadian Mounted Police Superannuation Act and makes consequential amendments to other Acts.
The Canadian Forces Superannuation Act is amended to change the limitations that apply in respect of the contribution rates at which contributors are required to pay as a result of amendments to the Public Service Superannuation Act.
The Public Service Superannuation Act is amended to provide that contributors pay no more than 50% of the current service cost of the pension plan. In addition, the pensionable age is raised from 60 to 65 in relation to persons who become contributors on or after January 1, 2013.
The Royal Canadian Mounted Police Superannuation Act is amended to change the limitations that apply in respect of the contribution rates at which contributors are required to pay as a result of amendments to the Public Service Superannuation Act.
Division 24 of Part 4 amends the Canada Revenue Agency Act to make section 112 of the Public Service Labour Relations Act applicable to the Canada Revenue Agency. That section makes entering into a collective agreement subject to the Governor in Council’s approval. The Division also amends the Canada Revenue Agency Act to require that the Agency have its negotiating mandate approved by the President of the Treasury Board and to require that it consult the President of the Treasury Board before determining certain other terms and conditions of employment for its employees.

Jobs and Growth Act, 2012

[Thomas Mulcair, NDP, Outremont, QC]

That the clauses mentioned in section (g) of this motion do compose Bill C-53; that Bill C-53 be deemed read a first time and be printed; that the order for second reading of the said bill provide for the referral to the Standing Committee on Health;

That the clauses mentioned in section (h) of this motion do compose Bill C-54; that Bill C-54 be deemed read a first time and be printed; that the order for second reading of the said bill provide for the referral to the Standing Committee on Citizenship and Immigration;

That the clauses mentioned in section (i) and (k) of this motion do compose Bill C-55; that Bill C-55 be deemed read a first time and be printed; that the order for second reading of the said bill provide for the referral to the Standing Committee on Environment and Sustainable Development;

That the clauses mentioned in section (j) of this motion do compose Bill C-56; that Bill C-56 be deemed read a first time and be printed; that the order for second reading of the said bill provide for the referral to the Standing Committee on Agriculture and Agri-Food; and

That the clauses mentioned in section (l) of this motion do compose Bill C-57; that Bill C-57 be deemed read a first time and be printed; that the order for second reading of the said bill provide for the referral to the Standing Committee on Human Resources, Skills and Social Development and the Status of Persons with Disabilities;

That Bill C-45 retain the status on the order paper that it had prior to the adoption of this order; that Bill C-45 be reprinted as amended; and that the law clerk and parliamentary counsel be authorized to make any technical changes or corrections as may be necessary to give effect to this motion.

Mr. Speaker, we are proposing this motion to better study individually in the appropriate parliamentary committees this omnibus budget bill, which touches on dozens of different pieces of legislation. We find this motion to be in the interests of this parliamentary institution that has been so hard pressed by a Conservative majority that thinks it can run roughshod over the rights of Parliament.

[The Acting Speaker, Conservative, Barry Devolin]

Does the hon. member have unanimous consent to move the motion?

[Some hon. members]

Agreed.

No.

[The Acting Speaker, Conservative, Barry Devolin]

He does not.

The time for government orders has expired. As such, the member will have a period for questions and comments when this matter returns to the House.,

It being 5:32 p.m., the House will now proceed to the consideration of private members' business, as listed on today's order paper.

Bill C-45--Notice of time allocation motion

[Peter Van Loan, Conservative, Leader of the Government in the House of Commons]

Mr. Speaker, I rise on a point of order. Our economic action plan is working and it has helped support the creation of over 830,000 net new jobs since the downturn, but there is more to do. To continue this work we need to implement our plan for the passage of Bill C-45, the jobs and growth act.

I would like to advise that an agreement has not been reached under the provisions of Standing Order 78(1) or 78(2) with respect to the second reading stage of Bill C-45, a second act to implement certain provisions of the budget tabled in Parliament on March 29, 2012 and other measures. Thus, under the provisions of Standing Order 78(3), I give notice that a minister of the crown will propose at the next sitting a motion to allot a specific number of days or hours for the consideration and disposal of proceedings at this stage. It is my intention to propose four further days for the second reading debate of Bill C-45.

Bill C-45—Time Allocation Motion

[Peter Van Loan, Conservative, Leader of the Government in the House of Commons]

moved:

That, in relation to Bill C-45, A second Act to implement certain provisions of the budget tabled in Parliament on March 29, 2012 and other measures, not more than four further sitting days shall be allotted to the consideration of the second reading stage of the bill; and that, 15 minutes before the expiry of the time provided for government orders on the fourth day allotted to the consideration of the second reading stage of the said bill, any proceedings before the House shall be interrupted, if required for the purpose of this order, and, in turn, every question necessary for the disposal of the said stage of the bill shall be put forthwith and successively, without further debate or amendment.

[The Speaker, Conservative, Andrew Scheer]

Pursuant to Standing Order 67.1, there will now be a 30-minute question period.

I would ask hon. members to try to keep their questions or comments to about a minute and the response to a similar length of time.

As we have been doing for some time now, we will treat this like question period with more questions being given to the opposition parties, but the government will have some opportunities throughout the rotation.

Questions and comments, the hon. member for Skeena—Bulkley Valley.

[Nathan Cullen, NDP, Skeena—Bulkley Valley, BC]

Mr. Speaker, thank you for that direction. I hope it is not too much like question period in the sense that when we ask a question of the government, we might get an actual answer. Hope springs eternal.

I am just going to quote my hon. friend across the way, the government House leader, who just last week said, “I look forward to a vigorous policy debate on the economy and not on procedural games”. Yet the first thing the government chooses to do today is to play procedural games.

There are two questions being put before the House. One is time allocation, closure, shutting down debate on this omnibus budget bill and the second is something the Conservatives used to decry when the Liberals did it. They are ramming together a whole bunch of issues, which have nothing to do with the budget at all. The Navigable Waters Protection Act has been getting some obvious attention. An environmental protection act that was used to protect Canada's environment from things like pipeline leaks is now rammed into a budget bill.

If my hon. friend across the way said he was looking forward to a debate and not procedural games, then why is it that the first thing the government has chosen to do is to use procedural games to shut down debate on such a massive 450-page omnibus budget bill, which the government admits contains so many things that were not in the budget. In fact, the Minister of Transport had to delete web pages in the middle of the night that referred to the Navigable Waters Protection Act as an act that actually protects the environment. That was not in the budget despite what the international affairs minister says. He says, “Look on page 282. There it is in black and white”, but we look and it is not there.

I am wondering where those principles and scruples that the Conservatives used to have about some basic democratic values went. Those fundamentals said that the House of Commons should hold the government to account, that the budget is the major document the government moves every year and that it is the duty and responsibility of all MPs, not just those in opposition but in government, to hold the government to account. The first thing the Conservatives do is play a procedural game by shutting down debate in this place, prematurely, on such an important document as the budget.

[Ted Menzies, Conservative, Minister of State (Finance)]

Mr. Speaker, I do hope that the next 30 minutes will not be filled with just questions about process. There is a lot more happening here fundamentally about democracy. We recognize that we are in extenuating circumstances. We are part of a global recovery and we all realize that. The budget that was tabled on March 29 is a continuation of our plan for jobs and growth, our plan for getting back to balance in the medium term. We are putting forward a comprehensive budget implementation act and we recognize that it needs to be discussed.

That is why we need to move it past this phase where the opposition tends to just talk about process. All we are asking for is to send the bill to committee expeditiously. We are going to spread it across 11 committees and that motion will be moved as soon as it is appropriate in a committee process. We want to get the bill to committee so that people can have some input into this, witnesses can be called on all different facets of this comprehensive piece of legislation and we can hear them out and move forward with what is necessary.

[Ted Hsu, Liberal, Kingston and the Islands, ON]

Mr. Speaker, I would like to bring up an example of a matter that deserves more consideration in this chamber before it goes to committee. That is the matter of the reduction of certain tax credits related to scientific research and experimental development. This is hundreds of millions of dollars in tax credits that is going away. If I were in a hurry I would probably do something that people on the other side of the floor would do, which would be to call this a tax increase since it is the elimination of a tax credit. I am sure the government would not want me to do that. This is a good example of something that has a rather complicated effect on businesses and something that affects hundreds of millions of dollars in taxes that would now be paid by businesses in Canada every year.

As a result of its size and because of its complexity and because of its importance to the economic future of this country, I believe that this legislation is an example of something that deserves more discussion in this chamber before it goes to committee.

[Ted Menzies, Conservative, Macleod, AB]

Mr. Speaker, that is exactly the point I was trying to make. Too often in here we hear discussions about process. The hon. member is correct. This is a complex improvement to the scientific research and experimental development tax credit. It is very important that we get this to committee, so we can actually talk about it and have witnesses come forward who actually understand this. I would argue that probably most members of Parliament could not explain how the SR&ED program actually works. It is a well-functioning program.

In my private life previous to politics, I was involved in SR&ED tax credits. They are very effective. They work well for innovators in the country. However, we heard from the Jenkins panel that we could do it better. That is what we are trying to do. It is a reflection of what Tom Jenkins had suggested to us as improvements. Let us get it to committee and talk about it.

[Guy Caron, NDP, Rimouski-Neigette—Témiscouata—Les Basques, QC]

Mr. Speaker, the Minister of State said that we must not boil things down to just process.

The government has just moved a time allocation motion, another means of shutting down parliamentary debate. The motion is about process, and that is nothing new for this government. Closure, prorogation and omnibus bills are all types of processes that the government uses to weaken the democratic framework in which we are supposed to work.

The Minister of State told us again that all they want to do is send the bill to committee as quickly as possible in order to study it. Canada is a parliamentary democracy with a clear parliamentary process: we have automatic first reading of a bill, and then second reading of the bill that members are supposed to do here in the House of Commons, before it can be studied in more detail by the Standing Committee on Finance and other committees, which the government is going to let happen, for once.

We currently have a problem. As was the case in June with Bill C-38, we will have an expedited debate and, even though the bill is going to be studied by various committees, we will not have the opportunity to give due consideration to the different elements of this omnibus bill that could be split off and passed independently.

The Minister of State was boasting about Bill C-38 and said that more than 150 witnesses had appeared before the committee, which sat for more than 75 hours. I would like to remind members that Bill C-38 covered 70 laws that were amended, added or rescinded. That comes down to two witnesses per law, whereas we generally hear from 15 to 20, and about one hour per law being amended.

Therefore, I would like to know why the government is using closure, omnibus bills and prorogation to water down the parliamentary work we were elected to do, as representatives of our constituents here in the House.

[Ted Menzies, Conservative, Macleod, AB]

Mr. Speaker, all members, who are members of the committees where the budget implementation bill will be sent, will have ample opportunity to speak to the experts who can bring topics to each one of these committees. That is exactly what we want to see.

As I suggested earlier, once again we have a process question, when we could actually be spending time talking about the substance of the bill. That is not good use of the House's time. We should actually be talking about the good things that are in the bill. We should be talking about the continuation of this plan, a plan that has actually seen us grow jobs in the country, more than 820,000 net new jobs since the end of the recession. That is a good number.

Obviously the plan is heading in the right direction. This is just a continuation of that plan. Let us move forward, get it to committee and discuss it at length.

[Matthew Dubé, NDP, Chambly—Borduas, QC]

Mr. Speaker, I found it interesting to hear the Minister of State say that members of Parliament are not necessarily experts and that we must hear from experts in committee.

What does he think about the fact that we speak on behalf of our constituents? We are experts on conveying the wishes of the people we represent. Our constituents deserve to have us speak on their behalf here in the House.

When the budget was tabled, the member for Burnaby—New Westminster read numerous emails, tweets and Facebook messages, among other things. That is how he shared the opinions of the public. I do not want to take anything away from the experts who testify in committee, but that is just one part of the parliamentary process. As my colleague pointed out, the most important part of this process is when we have the opportunity to do what we are doing now: rise in the House to represent the wishes of the people who elected us. I had the opportunity to speak to Bill C-38, and I was able to share what my constituents thought. No, these people are not experts, but we are accountable to them and we are here to represent them.

The Minister of State is dismissing the parliamentary process, when it is very important here. What is the purpose of Parliament if there is no parliamentary process? Is it a dictatorship? This process is the very essence of democracy, legislation and fundamental rights in a society. If the Minister of State thinks that this process is not important, I suggest that he find another profession, because I do not think he is in the right field.

When will the members opposite respect the parliamentary process? When will they recognize that we are here to speak on behalf of other experts—the people we represent?

[Ted Menzies, Conservative, Macleod, AB]

Mr. Speaker, I want to go back to the point about the discussions here. They are valid discussions, but each member of the House is a de facto member, an alternate member, of all these committees where this piece of legislation would go. Therefore, they would have ample opportunity for some in-depth discussion with those witnesses who wish to come and speak to the pros and cons of all these suggestions and what is in this legislation. To take advantage of the time we have here, I would encourage the members to ask questions about what the benefits are with respect to this legislation we are putting forward.

The hiring tax credit is one example about which I was hoping someone would ask me. We put it in last year's budget for small businesses, and it is very effective. More than half a million businesses were able to take advantage of it. If we can get the bill through, we are projecting that 536,000 more businesses will be able to take advantage of it, and perhaps the same businesses. That is a $200 million benefit to small businesses in this country. I bet we will have some witnesses come forward to say that is good.