Point 3.37 talks about the penalties for third parties. You are penalizing the external factors, if you will, but you do not mention the internal factors. There is no lifting of the corporate veil that is protecting some administrators and board members. A relatively effective solution would be banning them from boards of directors in Canada if they authorized aggressive tax planning. I do not see any such measures. Freelance tax experts are being punished but the boards of directors are not. The members who gave the authorization are not being held accountable.
On December 11th, 2014. See this statement in context.