I'd say, without over-exaggeration, every day.
I'll just back up for a second. I don't think this has been said today, but section 84.1 is the section of the act that accountants get sued on more than any other section of the act, because it's so prevalent, it's not logical and it's not fair. A practitioner who doesn't have a tax group gets caught by this. It's there all the time, because it doesn't just apply....
I have another example. If my client were to buy the company from his brother, who inherited it from their grandfather, there's so much information that will affect future taxation, and they may not have this information. If the brothers are not speaking.... My client, brother number two, needs to know what brother number one claimed for his capital gains exemption.
To answer your question, section 84.1 is so prevalent. It applies in virtually all.... It's always in the back of our minds for any private enterprise, whether or not they're going to sell to their family. Any time we do a restructuring, it could inadvertently apply and trigger a dividend when you didn't think there would be one.
This bill doesn't fix all that stuff, but it really fixes what it needs to start.