Dr. Jim Stewart:

That is certainly the case, as it is with regard to all hybrid instruments. That is why the European Union in response to the BEPS initiative has imposed restrictions on the use of hybrid instruments. It has, for example, limited interest payments that may be made by hybrid instruments. They can involve double non-taxation and for that reason, I think their use will tend to be phased out. In addition, EU commitments and attempts to reduce the use of shell companies may also affect section 110 companies. It defines a shell company as a company with no employees and no fixed assets. Both those forces may reduce the number of hybrid instruments and their use in financing companies.