To my knowledge, there have been no criminal convictions for international tax evasion in Canada, at least within the last decade. This is to be contrasted with the Americans, where there hasn't been a whole bunch, but there have been select cases. They've highlighted them; they've publicized them. The U.S. Senate put all the names in the report. And that does act as an effective deterrent.
When you talk to crown attorneys in Canada or to people who work for the justice department and consider these potential prosecutions, they say they don't bring them forward. It's so difficult to get a conviction. It's this mens rea element. You have to prove beyond a reasonable doubt that the taxpayer had a guilty mind. They were not trying to avoid taxes in an aggressive fashion in the grey area of tax law, but they're actually trying to cheat the government out of taxes.
It would be a good idea for our crowns to identify a special case where it's quite obvious the person is engaged in tax evasion. They have evidence of this guilty mind and make an example out of that person. That, combined with a temporary amnesty, would be a nice combination.