That was a good summary, but that's not quite it. I will explain things again.
Since the recent amendments made to section 5907 of the Income Tax Regulations, we know that if Canada signs an agreement to exchange tax information with a tax haven, this will affect the Canadian multinationals that earn business income in that specific tax haven. Indeed, the act was amended in such a way that business income earned in that tax haven could be repatriated to Canada tax free. That was the effect of the recent changes to section 5907 of the Income Tax Regulations. Thus, if a Canadian multinational makes profits that are considered business income in any of the tax havens I referred to in my presentation, that business income will not be taxed in any way, neither in Canada, nor in the tax haven if that country does not collect any income tax.
The rules on the upstream loans intend to catch the multinationals that are attempting to avoid the repatriation income tax. However, at the same time, the legislator is adopting other regulations that allow for the legal cancellation of the repatriation income tax. One can be forgiven for wondering: why bother introducing rules on upstream loans, since there will no longer be any repatriation income tax on the income earned in most tax havens? Clearly, the multinationals are not going to try to put in place strategies to avoid this income tax which no longer exists.
Was that clearer?