I'm going to give you the same answer that Mr. Barrett gave earlier. Unfortunately, I cannot say that I am not a lawyer, because I am. Nevertheless, I really do not know.
We've seen both sides of the coin. We state our position in our presentation; the presentation of the Canadian Film and Television Production Association mentions this as well.
What is clear is that this seems to be an obligation set out in the regulations, whatever the proper time for implementing it may be.