Yes, that's right.
Your description of the proposal is not exactly correct. It's about half correct. It is true that it requires the reporting of what we call an avoidance transaction. It's defined in the tax law. But it's only a reporting of that avoidance transaction if also there are two out of three hallmarks present—what we call hallmarks.
Just first, on what an avoidance transaction is, an avoidance transaction is not necessarily something that's abusive. An abusive avoidance transaction would be subject to the general anti-avoidance rule. That requires another step for the CRA to reassess, that is, the CRA would have to show that the transaction or series of transactions actually represents an abuse of the tax law. This rule for reporting applies just for simple avoidance, if you want to call it that.
What is an avoidance transaction? It is one where the purpose of the transaction is more for tax than for any other purpose, and it could involve a series of transactions where there may be a commercial purpose to the series of transactions. But if there is a transaction in the series and the purpose of that transaction in the series is not for a commercial purpose but it is for a tax purpose—that is, the purpose is to receive a tax benefit—then the whole series will be considered to be an avoidance transaction. So that's the first thing. To be an avoidance transaction, you didn't do this as much for commercial purposes as you did it to lower your taxes.
The second thing is the hallmarks—two out of three hallmarks. And what's a hallmark? It's a set of circumstances under which—