IFS kit licensing question


I am a software developer managing an antivirus project licesed under
GPL. We are considering writing a file system filter as a part of the
project. This would require Windows 2003 IFS kit.

Before ordering an Windows 2003 IFS Kit I have a question:

If we develop a driver from scratch without using IFS kit samples can we
then distribute it as GPL in both object code (compiled using DDK with
#include <ntifs.h>) and source code? We would not distribute ntifs.h or
any other part of the IFS kit along with the software.

With kind regards,