I'm a CA and I work with a number of tax lawyers, who uniformly tell me that the draft legislation, especially in the area of capital gains/dividend arbitrage, is a complete mess.  These are the provisions that drive the tax rate on estates to 50, 70, or even 90 per cent versus the old max of about 25.  If Morneau intended that, he should say so.  It is more likely that CRA and The Department of Finance got overzealous and created what is now a giant political headache for Morneau.  From what I've seen and read, there are virtually no tax lawyers on side with what is on offer, and it is obvious why.