Sure.
Very quickly, I want to note, with respect, that the general anti-avoidance rule was recently significantly amended, and it has passed through Parliament, so that has in fact happened.
From a CRA perspective, again, I don't want to be disparaging against the CRA as an organization entirely. There are a lot of great people who work at the CRA who do a lot of great work. Unfortunately, as with any large organization, there are some auditors who spend a lot of time on an audit and then feel at the end of it that they need to show something for their effort, so whether it's because they're concerned with a TEBA, tax earned by audit, statistic or otherwise, in some cases they'll audit taxes that should never have been audited and should never have been assessed.
It's doing whatever the CRA can as an organization to prevent those instances. When they do occur, the CRA should try to identify what the root causes are, whether it's poor training, not enough supervision or just having the right incentives within the organization to ensure as best as possible that audits are accurate and not overturned on appeals or by the courts.