Why wouldn't you do that? If you knew that you could take that step—and you've already said that you value the expertise of CRA so much that you'd hire them, even though they have cooling-off periods—why wouldn't you take the step of making sure that...? Given you are on a thin line between tax evasion and tax avoidance, knowing the difference in law, why wouldn't you take that extra step to give your clients the assurance that they wouldn't be put through a legal test, which is extremely expensive, or that they wouldn't be found in contravention of the spirit of the law in Canada?
On May 3rd, 2016. See this statement in context.