It is, and I apologize for getting a little bit into the weeds, but I think that's important to understand it.
There are a lot of techniques used in cross-border mergers and acquisitions planning. This doesn't affect the most common of them. For example, I think probably tax planning 101 is to establish a Canadian acquisition corporation, fully funded with the purchase price by a non-resident, who would use it to buy the Canadian target. That would not be affected.
What would be affected is, as I described earlier, in-house reorganizations that, essentially with a non-resident parent on top, try to get into the exception we're dealing with in subsection 212.1(4), but there are a number of examples, such as the one I just described, that would not be affected. I think it's probably, and certainly from my experience, the most common way of doing it.