We can't confirm that the document on the website is from the CRA. But, generally speaking, in a settlement case, the process is completely separate from the applicable voluntary disclosures program.
In the case of a settlement, we consider the facts, the legal risks, and the country's tax interests. Then we make a determination. In some cases, when the issue is principle-based, we don't enter into a settlement agreement. If a legal precedent can be set, the CRA does not negotiate a settlement agreement.
When we are 100% sure of the facts, we do not enter into a settlement agreement. It's the legal risk, where applicable, of not having the names—