Two separate gates in the Investment Canada Act run on no dollar figure whatsoever — and one of them can extend the deadline on an otherwise routine review.
Short answer
Yes. Two Investment Canada Act mechanisms apply to a foreign buyer regardless of deal size — a discretionary review for a prescribed cultural-heritage business under s.15, and a national security review under Part IV.1 — and neither one is switched off by clearing, or by falling under, the ordinary net-benefit dollar thresholds. A deal can be too small to need net-benefit approval and still be ordered up for review under either provision.
Section 15 of the Investment Canada Act reads: “An investment subject to notification under Part III that would not otherwise be reviewable is reviewable under this Part if (a) it falls within a prescribed specific type of business activity that, in the opinion of the Governor in Council, is related to Canada's cultural heritage or national identity; and (b) within 45 days after the certified date … the Governor in Council … issues an order for the review of the investment, and … the Director sends the non-Canadian … a notice for review.” The trigger is the type of business, not its size — a routine notification filing on an ordinary-looking small deal can still land inside that 45-day window if the target's activity is prescribed as cultural.
Section 25.1, which opens Part IV.1, states: “This Part applies in respect of an investment, implemented or proposed, by a non-Canadian (a) to establish a new Canadian business; (b) to acquire control of a Canadian business in any manner described in subsection 28(1); or (c) to acquire … an entity carrying on all or any part of its operations in Canada” if that entity has a place of operations, employees, or assets in Canada. There is no dollar figure anywhere in that provision. It can also run in parallel with an ordinary net-benefit review rather than replace it: under s.21(2), if a national-security notice under s.25.2(1) issues before the usual 45-day net-benefit deadline, that deadline is itself extended to run 30 days past the end of the security review's own prescribed period.
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