Earlier today we did talk about this and I attempted to sort of explain the difference between what I'll call the civil side versus the criminal side.
It's basically a burden of proof. When we raise tax assessments based on tax avoidance, it's simply a question of preponderance of evidence, whereas when we go the criminal route, tax evasion, it's beyond a reasonable doubt.
It's essentially the level of documentation and proof we need to have, in consultation with our colleagues in Justice, to prosecute a case of tax evasion.