Right now that's the biggest issue that we have with the draft legislation. Under the draft legislation, private trusts, private holding companies, are not Canadian financial institutions. They're not FIs. And for those type of entities that have purely Canadian affairs, that's going to be just fine. But when those entities have U.S. accounts or U.S. affairs, or they have an interest in a U.S. REIT or limited partnership, that's where we're going to have the problem. That's where there's going to be withholding on payments to those type of entities, because although it's a non-financial institution under Canadian domestic law, the U.S. withholding agent has to follow U.S. law, and under U.S. law it's something different. When there's a discordance in classification, the withholding agent is obligated to withhold.
On May 13th, 2014. See this statement in context.