I can't comment on a specific taxpayer file. I can speak, though, in general terms about the agreement that is posted to the CBC website and how the CRA generally reaches those kinds of agreed-to settlements.
In such cases, payment within 60 days is a clause in such agreements, guaranteeing that the agency would be paid. I would also point out that the agreement on the CBC website talks about 15 years, in other words going back 15 years. Back to your earlier remarks regarding the CRA, in a traditional compliance review, we look at one tax year. Let's fix the mistake, and let's move forward, back to the voluntary compliance.
In our audit program, we do 120,000 audits. We usually look at one to four tax years. Let's clean it up. As with the statute of limitations, we have statute-barred. We can go back only so far.
In the case of aggressive tax planning—the people who engage in tax shelters and those kinds of moves—we actually have the right to go back six years. We go back six full tax years and charge compound interest. A careful reading of the document posted to the CBC website, which I can't confirm is an actual offer of agreement, would indicate that we went back 15 tax years. That would be consistent with CRA's approach to offshore tax evasion, the most serious kind of non-compliance that we detect. We vary our approach based on the seriousness.