The Auditor General observed that this was actually unfair, that Canadians who didn't have offshore accounts were automatically denied a claim or deduction if they couldn't produce documents in 90 days.
What I would like to know is whether there has been any progress on providing more fairness to Canadian taxpayers who will automatically lose their deduction in 90 days, compared with offshore filers who can defy with impunity a request for documents from the CRA.