Thank you for this follow-up question, because it was a comment I was hoping to jump in on earlier.
I don't think the fact that a transaction is not actually found by the CRA or by the courts to work, if you will, technically, makes it tax evasion. There may be circumstances in which a taxpayer takes a position that the tax payable is such and so because of the transaction they've undertaken and their interpretation of the law. They may file a full report of that in their return of income. The fact that CRA disagrees, challenges it, and wins does not make that tax evasion on the part of the taxpayer. There can be other circumstances in which the taxpayer seeks not only to take a position but also to hide that position, which could move it over to being tax evasion, but just losing to CRA does not make it tax evasion per se.