That is a good question to which I do not have the answer. I assume that Revenue Canada employees are highly qualified and that it would be beneficial to have more agents working on this type of problem. We also confront the same problem in the world of insurance. We know that Canadian companies are forced to create offshore companies in order to receive the same tax treatment as foreign companies operating in Canada. Mutual insurance companies that do not have an offshore company are at a fiscal disadvantage, compared to their competitors.
On September 26th, 2006. See this statement in context.