Mr. Chair, I can respond to that question.
This amendment is actually a response to a court case from 2018. The court of appeal in that case determined that the general anti-avoidance rule was not available in situations where a transaction had been done to create tax attributes, but those attributes had not yet been used. Prior to that court case, it was the CRA's policy to use an issuance of what's called a notice of determination to apply the GAAR to unused tax attributes through this process. This court case determined that the GAAR conditions are not satisfied in a situation where those tax attributes have not been used yet.
The purpose of this amendment is to change those technical requirements with respect to the general anti-avoidance rule so that the CRA can continue to issue notices of determination before tax attributes have actually been used. This is really intended to just revert back to that 2018 situation.