Perhaps sight is being lost of the basic point. First of all, this is taxpayers' money and these are the same rules we're talking about in this context that apply to each and every one of us. When we have an overpayment and are entitled to a tax refund from Revenue Canada, the rate of interest paid on that refund is the same for individuals and corporations.
The question here is whether corporations in particular are overpaying to provide for potential reassessments, and treating CRA as an investment bank. It seems that CRA and the AG's own report have had the right policy since the outset. There is only to be an acceptance and holding of such deposits when reassessments are likely. The verification of that is the point that seems to be at issue, and the commissioner has spoken to that.