I think the one concern with that is that there is a statement in the context of the CRA's guidance documents that they will work to protect the identity, and I'm not sure what the phrasing is, but it's to the effect of “to the extent possible”, something like that.
I think that this is a good start, but at the end of the day, it is simply an interpretation. It's simply a guidance document that has been posted on their website. There are limited ways that taxpayers or informants could enforce those types of statements, and including even a statement of the same type of principle in a legislative provision or in a regulatory provision will give that much more comfort. However, there are ways to beef up that kind of protection.
The Income Tax Act itself defines protections like solicitor-client privilege. There would be the ability to extend a broader protection in a legislative provision saying the identity will not be disclosed except in these types of circumstances. I think that this is a policy choice to decide precisely how far Parliament wants the protection to go, but I think the point is that the choice should be made, rather than simply leaving it as a vague comment that may or may not be enforced against the CRA.