Very often, in fact, these changes stem from agreements with the Canada Revenue Agency. What happens is a taxpayer, be it a company or an individual, proposes using a tax code or asks the Canada Revenue Agency whether it would accept a specific procedure, given a legal vacuum in the Income Tax Act. The Canada Revenue Agency then decides whether or not that use is acceptable.
However, even if the Canada Revenue Agency determines that the proposed procedure is acceptable, the Income Tax Act isn't automatically amended. Consequently, some of the Canada Revenue Agency's decisions in these cases date back 10 or 15 years and have yet to be incorporated into the Income Tax Act. Very often, what that does is negatively affect other amendments that are subsequently proposed by the Canada Revenue Agency. These kinds of situations create a lot of confusion because the Income Tax Act is silent on them.
Technically, upon examination, the government proposes these amendments so that they can be adopted, thereby giving all members of the tax community, experts, advisors and so forth, a uniform understanding of the legislation and the decisions that were made.