In cases of straightforward civil assessments, it's the balance of evidence which applies. In that situation, there are several ways we can use to get the information we need. There would be information in the country, banking information which can be obtained in Canada and, if necessary, under tax conventions with other countries.
However, the situation is very different in the case of tax avoidance. You have to prove that beyond a reasonable doubt, and that is much more difficult. The balance of evidence would then become much more significant. Furthermore, under Canadian law, people have the right to protection. In cases where we would want to force a taxpayer to provide us with information, our power changes drastically in cases of tax avoidance. There would be criminal consequences, as opposed to just having a civil assessment.