Basically, as you pointed out, an individual taxpayer who's being challenged by the agency to provide additional information on a receipt is given 90 days to respond. If they don't really respond or provide that information, they're automatically disallowed—the receipt or the deduction—and they're reassessed, whereas when you look specifically at offshore transactions, again, they can make requests for additional time due in some cases to complexity—
On November 26th, 2018. See this statement in context.