Sure.
There was a change to the Bank Act. Before, a foreign bank that wanted to operate in Canada had to incorporate a company, incorporate the bank, to operate as a full person, basically. Since the change to the Bank Act, foreign banks have been entitled to operate as a branch.
Basically, the legal person is still the foreign bank; they have only a branch in Canada. Before, they were not allowed to operate as a branch in Canada. Now they're allowed to. Maybe when they came to Canada the first time the bank could have chosen to operate as a branch and not necessarily as a subsidiary of the foreign bank. To do that now, what could have happened is that when transferring assets from....
Let's say they want to close the subsidiary and just operate as a branch. There would be a sale of assets. Usually when there's a sale of assets, there's GST applying. Under the GST we have rules that basically allow for a rollover of transactions when there's the sale of a business. But in this situation, where you receive representation, the existing rule would not apply in every case.
So basically we put in place a transitional measure. For a certain period of time, the foreign bank can use the new rollover provision to avoid payment of tax on the restructuring of their operations.