No. They have been paying it. That's exactly the issue. They've been paying it and contesting it for the better part of 20 years. It was only when they got, frankly, to the point where they took it to court, and ultimately the government lost, that all of a sudden this came about.
What happened was—just to be clear—the institutions paid it. They would file a request with CRA for, in effect, a tax paid in error. CRA would do nothing. Eventually, CRA denied a claim. That's what precipitated the court case. The facts of the matter were heard, and the government lost at the Federal Court of Appeal. The government could have appealed to the Supreme Court, had it wanted to. It chose not to do that, which speaks volumes about the strength of its case. It then sat on its hands for two years. Finance said nothing, then, all of a sudden, retroactive legislation comes out that effectively tries to erase 20 years' worth of history.