The big loophole would be surplus-stripping. Then there's an important exception to that rule when you have—I'll provide a bit more background—a Canadian entity buying a foreign company that happens to own another Canadian entity. You could say that the foreign target in that purchase is sandwiched between the two Canadians.
For a number of reasons, you want to unwind that sandwich and move the bottom Canadian company up. That might ordinarily be caught within the surplus-stripping rules, so there's an exception saying that if you have a Canadian company that buys a foreign target with a Canadian sub, you are allowed to unwind it.
The specific amendment here deals with foreign parent companies reorganizing to work their way into that exception in cases in which it really isn't a Canadian entity buying a foreign target, but a foreign parent establishing a Canadian entity that has another foreign entity; cases in which they are trying to get into this situation.
In terms of cross-border purchases and sales of shares, this basically clarifies an existing exception to an anti-avoidance rule that prevents people in inappropriate circumstances from essentially either stripping Canadian—