Sure. I was speaking to a tax practitioner last week and they talked about a case of succession, so either on the death of the parents or planning for that eventuality, the business was transferred to the children.
That scenario gives rise to a lot of voluntary disclosures. If they follow the voluntary disclosure route and CRA hasn't initiated any audit or enforcement action, upon payment of all the tax and all the arrears interest owing, they wouldn't be subject to any penalty.
If they choose the different path, first of all, the practitioner could be liable for criminal prosecution or third party sanctions, which aren't criminal but monetary, and the individuals upon conviction could be liable for up to 200% of the tax owing. That's quite a different outcome in tax administration.