REASONS FOR JUDGMENT
Smith J.
INTRODUCTION
[1]
Marc Filiatrault, the appellant in this
proceeding, is appealing a decision by the Minister of National Revenue (the “Minister”)
under the Excise Tax Act, R.S.C., 1985, c. E-15 (the “ETA” or “Act”)
dated March 24, 2016, that confirms the notices of assessment and adjusts the
amount of his net tax, plus interest and penalties for failure to file.
[2]
The notices of assessment were established on June
5, 2015, for the period from February 1, 2013 to December 31, 2013, and on May
27, 2015, for the period from January 1, 2014 to December 31, 2014, (“the
period in question”).
[3]
The ETA provides that certain health care
services are exempt, i.e. that the Goods and Services Tax (“GST”) does not have
to be collected. The services that benefit from this particular treatment are
set out in Part II of Schedule V of the ETA. Therefore, any services not
mentioned there are excluded and therefore subject to the GST.
[4]
The Minister alleges that the appellant failed
to collect and remit the GST when he was required to do so, since psychotherapy
services rendered by an orientation counsellor are taxable supplies and are
therefore not exempted under the ETA.
[5]
With regard to the interest and penalties, the
Minister submits that the appellant did not demonstrate that he exercised due
diligence to discharge the amounts imposed on him pursuant to section 280
of the ETA.
THE ISSUES
[6]
The issues are the following:
i)
Could the Court find that the services offered
by the appellant are psychotherapy services?
ii)
Are these services “a qualifying health care
supply” within the meaning of the ETA and, if so, does the appellant render “psychological
services” as a “practitioner” within the meaning of the ETA?
iii)
Was the Minister correct to impose penalties for
the failure to file a GST return pursuant to section 280 of the ETA?
SUMMARY OF THE FACTS
[7]
The appellant has been an orientation counsellor
since 1985.
[8]
In 1989, he decided to reorient his career and
began training to become a psychotherapist. In 1990, he began to work in a
psychiatric hospital as a counsellor in orientation and rehabilitation. In
1995, he was accredited by his professional order to practice psychotherapy. In
2012, a psychotherapist’s permit was issued to him by the Ordre des
psychologues du Québec. Since then, according to his testimony, he no longer
offers any services as an orientation and rehabilitation counsellor because he
essentially only offers psychotherapy services in private practice.
[9]
When he was accredited by his professional order
in 1995, psychotherapy was not a professional activity that was regulated at
the provincial level. However, in 2012, the province of Quebec amended the Professional
Code, RSQ, c C-26 (the “Code”) and, following these amendments, the Ordre
des psychologues du Québec had the power to issue psychotherapist’s permits.
The appellant’s competence was recognized by this Ordre and a psychotherapist’s
permit was issued to him on September 26, 2012.
[10]
The Code states that psychologists and
physicians have the capacity to practise psychotherapy as well as, since 2012,
members of the Ordre professionnel des conseillers et conseillères d’orientation,
and psychotherapist permit holders, among others, as set out in section 187.1
of the Code.
[11]
In his testimony, the appellant states that his
patients are referred to him by physicians or colleagues in the health care
network, for treatment of various symptoms, through psychotherapy services.
Indeed, the appellant developed a particular expertise in the treatment of
psychotic disorders, in the course of his experience in a hospital setting at
the Institut universitaire en santé mentale Louis H.
Lafontaine.
[12]
On cross-examination, the appellant acknowledged
that he also had training as a somatic instructor, which is an educational
approach to movement, similar to practising yoga. He tried to develop a
practice in this field, but was not very successful. During the period from
2014 to 2015, he had only a few clients who solicited his services in that
field. According to his testimony, he indeed included the amounts received for
those services in his income tax return.
[13]
According to the appellant, the parties and
various professionals in his field that were aware he had a permit from the
Ordre des psychologues du Québec, led him to believe that psychotherapy was a
service exempt from the GST.
[14]
Indeed, in 2013, he questioned his accountant on
the subject of collecting GST, and she told him that he was not required to
collect the tax given that his psychotherapist’s permit had been issued by the
Ordre des psychologues du Québec.
[15]
It was not until a conference in 2015 that a
colleague informed him that if he was a psychotherapist, he had to collect and
remit the tax, because the ETA did not exempt psychotherapy services. After
that, he took steps with the Ordre des psychologues du Québec and with the
Ordre des conseillers et conseillères en orientation, and they were not able to
give him a specific answer on the subject. He also tried to communicate with Revenu Québec for advice on the issue.
STATUTORY FRAMEWORK
[16]
With regard to the statutory framework,
subsection 165(1) of the ETA sets out the basic rule for imposing GST, stating
that every recipient of a taxable supply made in Canada must pay tax calculated
at the rate of 5%.
[17]
Subsection 123(1) of the ETA defines the
expression “taxable supply” as a supply that is made in the course of a
commercial activity. On that point, the definition of commercial activity in
the ETA specifically excludes “exempt supplies”. Subsection 123(1) states that
an “exempt supply” means a supply listed in Schedule V of the ETA, which
includes nine categories, one of which is “health care services”, in Part II.
[18]
For the purposes of the health care services
supply exemption, sections 1.1 and 1.2 refer to restrictions on the application
of Part II of Schedule V. Supplies from certain services that are not done for
medical or reconstructive purposes are specifically excluded. Also excluded
from the application of this Part, with the exception of some articles, are
supplies that are not admissible health care supplies.
[19]
Therefore, at the first stage of the analysis,
we have to see whether the services rendered could be qualified as a “qualifying
health care supply”, in order to be exempt:
|
Excise Tax Act
|
Loi sur la taxe d’accise
|
|
PART
II
Health Care Services
|
PARTIE
II
Services
de santé
|
|
1 In this Part,
|
1 Les
définitions qui suivent s’appliquent à la présente partie.
|
|
[…]
|
[…]
|
|
qualifying health
care supply means a supply of property or a
service that is made for the purpose of
|
fourniture admissible de soins de santé Fourniture d’un bien ou d’un service qui est effectuée dans le
but :
|
|
(a) maintaining
health,
|
a) de maintenir la santé;
|
|
(b) preventing
disease,
|
b) de prévenir la maladie;
|
|
(c) treating,
relieving or remediating an injury, illness, disorder or disability,
|
c) de traiter ou de soulager une blessure, une maladie, un
trouble ou une invalidité, ou d’y remédier;
|
|
(d) assisting
(other than financially) an individual in coping with an injury, illness,
disorder or disability, or
|
d) d’aider un particulier (autrement que financièrement) à
composer avec une blessure, une maladie, un trouble ou une invalidité;
|
|
(e) providing
palliative health care.
|
e) d’offrir des soins palliatifs.
|
[20]
Once it is established that a service meets the
definition of “qualifying health care supply”, it is necessary to determine
whether a specific section of Part II of Schedule V exempts that service. Section 7
provides an exemption for health care services that are specifically named,
rendered by a practitioner, including psychological services:
|
Excise Tax Act
|
Loi sur la taxe d’accise
|
|
PART
II
Health Care Services
|
PARTIE
II
Services
de santé
|
|
7 A supply of any
of the following services if the service is rendered to an individual by a
practitioner of the service:
|
7 La
fourniture d’un des services ci‑après rendu par un praticien du service
à un particulier :
|
|
(a) optometric services;
|
a)
services d’optométrie;
|
|
(b) chiropractic
services;
|
b)
services de chiropratique;
|
|
(c) physiotherapy
services;
|
c)
services de physiothérapie;
|
|
(d) chiropodic services;
|
d)
services de chiropodie;
|
|
(e) podiatric services;
|
e)
services de podiatrie;
|
|
(f) osteopathic
services;
|
f)
services d’ostéopathie;
|
|
(g) audiological
services;
|
g)
services d’audiologie;
|
|
(h) speech‑language
pathology services;
|
h)
services d’orthophonie;
|
|
(i) occupational therapy
services;
|
i)
services d’ergothérapie;
|
|
(j) psychological
services;
|
j)
services de psychologie;
|
|
(k) midwifery services;
|
k)
services de sage-femme;
|
|
(l) acupuncture
services; and
|
l)
services d’acupuncture;
|
|
(m) naturopathic
services.
|
m)
services de naturopathie.
|
[Emphasis added.]
[21]
It is noted that paragraph 7(j) of Part II of
Schedule V of the ETA recognizes that the supply of a psychological service is
exempt from the GST. However, the section requires that these services be
provided by a “practitioner” within the meaning of the definition given under
section 1 of Part II of Schedule V of the ETA:
|
Excise Tax Act
|
Loi sur la taxe d’accise
|
|
PART
II
Health Care Services
|
PARTIE
II
Services
de santé
|
|
Services de santé
|
1 Les définitions
qui suivent s’appliquent à la présente partie.
|
|
practitioner, in respect of a supply of optometric, chiropractic,
physiotherapy, chiropodic, podiatric, osteopathic, audiological,
speech-language pathology, occupational therapy, psychological, midwifery,
dietetic, acupuncture or naturopathic services, means a person who
|
praticien Quant à la fourniture de
services d’optométrie, de chiropraxie, de physiothérapie, de chiropodie,
de podiatrie, d’ostéopathie, d’audiologie, d’orthophonie, d’ergothérapie, de
psychologie, de sage‑femme, de diététique, d’acupuncture ou de
naturopathie, personne qui répond aux conditions suivantes :
|
|
(a) practises the
profession of optometry, chiropractic, physiotherapy, chiropody,
podiatry, osteopathy, audiology, speech-language pathology, occupational
therapy, psychology, midwifery, dietetics, acupuncture or naturopathy
as a naturopathic doctor, as the case may be,
|
a)
elle exerce l’optométrie, la chiropraxie, la physiothérapie, la
chiropodie, la podiatrie, l’ostéopathie, l’audiologie, l’orthophonie, l’ergothérapie,
la psychologie, la profession de sage-femme, la diététique, l’acupuncture
ou la naturopathie à titre de docteur en naturopathie, selon le cas;
|
|
(b) where the person is
required to be licensed or otherwise certified to practise the profession in
the province in which the service is supplied, is so licensed or certified,
and
|
b)
si elle est tenue d’être titulaire d’un permis ou d’être autrement autorisée
à exercer sa profession dans la province où elle fournit ses services, elle
est ainsi titulaire ou autorisée;
|
|
(c) where the person is
not required to be licensed or otherwise certified to practise the profession
in that province, has the qualifications equivalent to those necessary to be
so licensed or otherwise certified in another province.
|
c)
sinon, elle a les qualités équivalentes à celles requises pour obtenir un
permis ou être autrement autorisée à exercer sa profession dans une autre
province.
|
[Emphasis added.]
[22]
Given that the ETA does not define the term “psychology”,
we have to review the legislation of Quebec in order to define this term and,
more specifically, to determine whether the term “psychology” includes “psychotherapy”.
The Code provides the following:
187.1. With the exception of physicians
and psychologists, no person shall practise psychotherapy or use the title of “Psychotherapist”
or any other title or abbreviation which may lead to the belief that he is a
psychotherapist, unless he holds a psychotherapist’s permit and is a member of
the Ordre professionnel des conseillers et conseillères d’orientation et
des psychoéducateurs et psychoéducatrices du Québec, the Ordre professionnel
des ergothérapeutes du Québec, the Ordre professionnel des infirmières et
infirmiers du Québec or the Ordre professionnel des travailleurs sociaux et des
thérapeutes conjugaux et familiaux du Québec. (See notes 1 and 2 above)
Psychotherapy is psychological treatment for a mental disorder, behavioural disturbance or other problem
resulting in psychological suffering or distress, and has as its purpose to
foster significant changes in the client’s cognitive, emotional or behavioural
functioning, his interpersonal relations, his personality or his health. Such
treatment goes beyond help aimed at dealing with everyday difficulties and
beyond a support or counselling role.
The Office
shall establish by regulation a list of actions which relate to psychotherapy
but do not constitute psychotherapy within the meaning of the second paragraph,
and shall define those actions.
[Emphasis added.]
[23]
As stated above, the ETA at Part II of Schedule
V, exempts many health care services, but psychotherapy services rendered by an
orientation counsellor holding a psychotherapist’s permit are not specifically
mentioned.
ANALYSIS AND CONCLUSION
A. The
nature of the services rendered
[24]
In this matter, the Court must determine whether
the psychotherapy services provided by the appellant are services exempt from
the Goods and Services Tax under Part II of Schedule V of the ETA.
[25]
However, the respondent submits that before
addressing the issue of law and interpretation on the taxation of psychotherapy
services, the appellant must demonstrate that he rendered those services.
Therefore, the Court must first determine whether the appellant discharged his
burden of establishing that he performs psychotherapy services.
[26]
On that point, the respondent submits that the
nature of the services rendered by the appellant is too broad and vague to
establish the nature. He submits in particular that the Court should draw a
negative inference from the fact that there is no documentary evidence that
corroborates the appellant’s testimony. The appellant points out that his
client files are confidential and that he cannot simply file them in Court.
[27]
Certainly, the appellant did not file any
documentary evidence that specifically describes the services that he offers.
However, in my opinion the testimonial evidence provided by the appellant was
credible and he discharged his burden to demonstrate the nature of the services
rendered as a psychotherapist.
B. Qualifying
health care services?
[28]
In the context of the analysis of this case, it
is important to note, first, that even if the ETA is a taxation statute that is
intended to increase the government’s revenues, it also includes political
taxation objectives, namely that taxpayers have access to health care services.
To do so, as described above, it provides that some of these services are
exempt from the GST.
[29]
First, to determine whether the services offered
by the appellant are health care services within the meaning of the ETA, it is
necessary to determine whether they qualify as a “qualifying health care supply”
within the meaning of the definition identified above.
[30]
In that respect, having found, above, that the
appellant offered psychotherapy services, it is my opinion that these services
were for “treating, relieving or remediating ... a disorder” within the meaning
of the definition. Therefore, these services may qualify as qualifying health
care supplies within the meaning of the ETA.
C. Psychological
services practitioner?
[31]
Paragraph 7(j) of Part II of Schedule V of the
ETA then provides that the supply of any health care services, including “psychological
services”, must be provided by a “practitioner” who dispenses these services.
Since the respondent admits that psychotherapy, as it is defined in section
187.1 of the Code, is included in “psychological services” within the meaning
of paragraph 7(j) of the ETA, the Court need not analyze this issue.
[32]
The Court must still determine whether the
appellant, an orientation counsellor who holds a psychotherapist’s permit
issued by the Ordre des psychologues du Québec, is a “practitioner” within the
meaning of section 1 of Part II of Schedule V of the ETA.
[33]
The appellant submits that he qualifies as a
practitioner within the meaning of the ETA. Indeed, he refers to the term “profession”
in the definition of practitioner. On that point, he submits that this term
does not refer to professions governed by a professional order, but rather that
it lists disciplines. Then, he argues that the nature of the services dispensed
must prevail, and not the person’s prior training. The Court does not accept
this interpretation.
[34]
The ETA is published in both official languages
and it is well established that we have to give them the same legal authority
(section 13 of the Official Languages Act, R.S.C., 1985, c. 31 (4th
Suppl.) and section 7 of the Charter of the French Language, CQLR, c.
C-11).
[35]
We observe, first, on reading the definition of “practitioner”
at section 1 of Part II of the ETA, that the legislator did not provide for
practising psychotherapy at paragraph (a). Further, with regard to the
definition of “practitioner” in the English and French versions, we note a
discrepancy. In the English version, it states that a person is a practitioner
within the meaning of the ETA if that person “practises the profession
of … psychology”, whereas in the French version, a person qualifies as a
practitioner if that person “elle exerce … la psychologie”.
[36]
In the event of a discrepancy between the two
versions, the rules of interpretation indicate that a two-tier test is
necessary. First, we have to find the common meaning between the two versions
and then determine whether this meaning is consistent with the legislator’s
intent: Pierre-André Côté, Interprétation des lois, 4e éd., Montréal Thémis,
2009, pp. 371 to 381.
[37]
In my opinion, the result of the common meaning
of these two versions is that to qualify as a practitioner offering
psychological services, that person must practise the profession of psychology.
[38]
We must therefore determine whether a
psychotherapist is a practitioner, namely a person practising the profession
who offers psychological services and, second, whether the person authorized to
offer psychological services as a psychotherapist is practising the profession
of psychology? I would answer both these questions in the negative.
[39]
As provided in the Professional Code at
section 187.1, psychologists and physicians can practise psychotherapy and,
since June 21, 2012, psychotherapy may also be practised by a person holding a
psychotherapist’s permit, with some conditions. Certainly, psychotherapy is a
service that falls within the scope of psychology, which the respondent
accepts. However, in my opinion, a psychotherapist cannot claim to practise the
profession of psychology.
[40]
In other words, even if the services offered by
a psychotherapist are psychological in nature, the ETA requires that the person
be a “practitioner”. In order to qualify in that respect, the requirement is
not only to offer psychological services, but to practise the profession of
psychology, which is reserved to psychologists who are members of the Ordre des
psychologues du Québec.
[41]
Therefore, even if the member of an order
specifically listed in section 187.1 of the Code is issued a
psychotherapist’s permit, that does not confer to that member the title of
psychologist, as required by the definition of “practitioner” within the
meaning of the ETA.
[42]
Further, I would add that this interpretation of
the definition of “practitioner” is consistent with the legislator’s
intent. In fact, in the wording of Part II of Schedule V, the legislator made a
very specific list of the health care services that are exempt from the GST
and, based on this wording, it is my opinion that these provisions should be
narrowly interpreted.
[43]
The provisions of Part II of Schedule V do not
expressly provide for an exemption from the GST for psychotherapy services
rendered by a psychotherapist, even if that psychotherapist holds a permit and
supplies a service in a province that regulates the psychotherapy profession.
The legislator’s omission is not without significance. A narrow interpretation
of the provisions leads us to conclude that if the legislator had wanted to
exempt these services, the legislator would have done so.
[44]
Accordingly, in my opinion, the interpretation
of the ETA does not support a finding that the services of a psychotherapist
rendered by an orientation counsellor, who holds a permit issued by the Ordre
des psychologues du Québec, are exempt within the meaning of the ETA. It
follows from this finding that these services are taxable.
[45]
In a similar matter, Williams‑Keeler v.
Her Majesty the Queen, 2013 TCC 28 (an informal proceeding), the issue was
whether the therapy services for trauma treatment that were provided by the appellant
were exempt services within the meaning of the ETA.
[46]
When the decision was rendered, the
authorization of the province of Ontario was not required to practise the trade
in question. The appellant, however, was certified by the Ontario Association
of Consultants, Counsellors, Psychometrists and Psychotherapists: paragraph 11.
[47]
Woods J. (as he then was)
found that, although the ETA provides an exemption for the health care services
listed in Part II of Schedule V, “[s]ervices by trauma therapists” are not
specifically listed. She adds the following:
[25] It may be the case that Ms.
Williams‑Keeler’s services are properly described as psychological in
nature, however, that is not sufficient for the services to qualify for this
exemption. The exemption also requires that the services be provided by a
practitioner, as that term is defined in section 1.
1. [...] 1. […] “practitioner”,
in respect of a supply of optometric, chiropractic, physiotherapy, chiropodic,
podiatric, osteopathic, audiological, speech therapy, occupational therapy,
psychological or dietetic services, means a person who
(a) practises the profession of
optometry, chiropractic, physiotherapy, chiropody, podiatry, osteopathy,
audiology, speech therapy, occupational therapy, psychology or dietetics, as
the case may be,
(b) where the person is required to be
licensed or otherwise certified to practice the profession in the province in
which the service is supplied, is so licensed or certified, and
(c) where the person is not required to
be licensed or otherwise certified to practice the profession in that province,
has the qualifications equivalent to those necessary to be so licensed or
otherwise certified in another province.
[26] Ms. Williams‑Keeler is not a
practitioner, as defined, because no licensing or certification was required to
practice in the area of trauma therapy in any province during the period at
issue.
[27] The representative for Ms.
Williams‑Keeler submits that she qualifies by virtue of her certification
by the Association of Consultants, Counsellors, Psychometrists and
Psychotherapists. He suggests that it is not necessary under the definition of “practitioner”
that certification be a requirement to practice. He submits that the word “required”
in paragraphs (b) and (c) above only applies to licenses and not
certifications.
[28] I
disagree with this interpretation. In my view, the term “required” in the
phrase “required to be licensed or otherwise certified to practice the
profession” is intended to apply to both licensing and certification. It makes
no sense for there to be a different test for licensing and certification.
[48]
She makes the following finding:
[33] I
would conclude that the exemptions relied on by Ms. Williams‑Keeler do
not include the trauma therapy services that she provides. Although there may
be good policy arguments in favour of exempting these services, this is a
matter for Parliament and not the courts. The appeal will be dismissed.
[49]
Except for the conclusion stated at para 26
of the decision, I agree with this analysis and find that the legislator
intended that persons who are practitioners, i.e. who practise one of the
professions listed, are also required to be members in good standing of their profession
in accordance with paragraph (b) of the definition of “practitioner”.
[50]
In this proceeding, the province of Quebec
decided to legislate and to make it so that a person who is not a psychologist
who offers psychotherapy services must obtain a psychotherapist’s permit —
which was not the case in the Williams-Keeler decision referred to above. In my
opinion, this does not change my finding that the appellant in this proceeding
was not practising one of the professions listed in section 7 of Part II, of
Schedule V.
D. The
penalties
[51]
In light of the finding stated above, it is
necessary to determine whether the Court can relieve the taxpayer of the
penalties imposed by the Minister under section 280 of the ETA, which
applies automatically when a tax report is not filed.
[52]
This provision reads as follows:
Interest
280(1) Subject to this section and section
281, if a person fails to remit or pay an amount to the Receiver General when
required under this Part, the person shall pay interest at the prescribed rate
on the amount, computed for the period beginning on the first day following the
day on or before which the amount was required to be remitted or paid and
ending on the day the amount is remitted or paid.
[53]
In the respondent’s pleadings, the respondent
argues that only the Minister has the power to waive these penalties under the
provisions of section 281.1 of the ETA. Accordingly, he argues that this
Court does not have the jurisdiction to set them aside. I do not agree with
this argument.
[54]
In fact, the Federal Court of Appeal in Corporation
de l’École polytechnique v. Her Majesty The Queen, 2004 FCA 127, confirms
that the reasonable diligence defence can be used against an administrative
penalty established under the scheme of section 280 of the ETA. The Court defines
the reasonable diligence defence as follows:
[27] This Court has held that there
is no bar to the defence argument of due diligence, which a person may rely on
against charges involving strict liability, being put forward in opposition to
administrative penalties.: In particular, it has held that section 280 of the Excise
Tax Act, by its wording and content, gives rise to that defence: Canada
(A.G.) v. Consolidated Canadian Contractors Inc., [1999] 1 F.C. 209
(F.C.A.). It may be worth reviewing the principles governing the defence of due
diligence before applying them to the facts of the case at bar.
[28] The due diligence defence allows a
person to avoid the imposition of a penalty if he or she presents evidence that
he or she was not negligent. It involves considering whether the person
believed on reasonable grounds in a non-existent state of facts which, if it
had existed, would have made his or her act or omission innocent, or whether he
or she took all reasonable precautions to avoid the event leading to imposition
of the penalty. See The Queen v. Sault Ste-Marie, 1978 CanLII 11 (SCC),
[1978] 2 S.C.R. 1299; The Queen v. Chapin, 1979 CanLII 33 (SCC), [1979]
2 S.C.R. 121. In other words, due diligence excuses either a reasonable error
of fact, or the taking of reasonable precautions to comply with the Act.
[…]
[Emphasis added.]
[55]
I find based on this, that “in order to
establish a due diligence defence to a penalty an appellant must show he either
(a) made a reasonable error in his or her understanding of the facts, or (b)
took reasonable precautions to avoid the event leading to the penalty”:
Comtronic Computer Inc. v. The Queen, 2010 TCC 55, paragraph 35.
[56]
On this subject, the respondent submits to the
Court that the appellant did not discharge his burden of proof with respect to
the penalties and that he did not prove the relevant facts justifying his
error. She submits that the appellant admitted that he learned, by chance, that
he had to collect the taxes from his patients and that it was only then that he
tried to obtain information.
[57]
According to the appellant, he contacted his
accountant in 2013 to see whether he had to collect GST for his psychotherapy
services and she told him that his services were exempt because he had a
psychotherapist’s permit from the Ordre des psychologues du Québec. He was also
misled by professionals in the health care network who told him that
psychotherapy services were exempt. It was not until 2015, at a psychotherapy
conference, that a colleague informed him that, even though he was a
psychotherapist, he had to collect the tax.
[58]
To summarize, in my opinion, the steps taken by
the appellant clearly show that he wanted to comply with the ETA. He therefore
showed reasonable diligence and for that reason the penalties at issue should
be vacated.
[59]
The appeal is allowed to vacate the penalties
but the assessment stands.
Signed at
Ottawa, Canada, this 22nd day of November 2017.
“Guy Smith”
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