That's a very difficult question, but I'll tell you the way I see it.
As I mentioned, it's in proposed paragraph 282.4(1)(b). That paragraph defines a “foreign entity”. It says that you're not allowed to influence elections if you are “a corporation or entity incorporated, formed or otherwise organized outside Canada”. If you were to end it there, then OPEN and all these other groups would be identified as foreign entities.
The trouble is that it goes on to exclude from that any entities that carry on business in Canada or “whose only activity carried on in Canada during an election period consists of doing anything to influence electors during that period”.
In other words, the foreign organization just has to do something—it could be bottle collecting, recycling, anything—so that it's not only conducting election-related activities.