A general response to a query as to whether negligence actions brought against CRA had affected tax administration, included statements that:
[W]here reliance is placed on a published view regarding a plain vanilla domestic tax arrangement, taxpayers should not be surprised that the CRA might take the view that the underlying facts and issues in an offshore structure would be sufficiently distinguishable to result in a challenge to taxpayer’s self-reported assessment of tax. …
[T]he CRA is committed to:
- Arriving at reasonable assessing positions that are timely and transparent;
- Communication to taxpayers when adopting positions that deviate from long standing interpretations, especially when there are publicly stated positions …
CRA also referenced its “commitment … to resolve disputes at the earliest possible stage.”