From my perspective—and I've been in the industry for 17 years dealing with GST issues on both sides—there is a lack of accountability and quality controls once the legislation is interpreted and appraisal standards are applied to the legislation. I think that creates the issue of applying legislation to appraisal standards and matching it with market information that's derived from transactions in the market.
I have an issue where, say, an auditor creates an incorrect $1-million reassessment. If that reassessment is disputed over the next three years and the Tax Court decides that it was wrong, the original auditor or team leader has no feedback loop where they can improve their processes or interpretations to eliminate the next problem assessment. Therefore, an audit file needs to have a time issue and associated costs all the way through the audit, appeal and tax procedures until the issue is resolved. That way we would have statistics on who creates those issues and how they can be resolved quicker, eliminating the time wasted on these disputes and the significant costs borne by both the taxpayer and the federal government.