The Aggressive Planning section manages "sham" assessments

Before a GST assessment based on “sham” is made, an auditor must prepare a position paper explaining that position and send it to the Aggressive GST/HST Planning Section - HQ for review, which then “works closely with the TSO in ensuring the two elements of sham are demonstrated” (i.e., deceit, as broadly defined in Antle, and actual legal rights which are different), and also approves the final assessment.

Neal Armstrong. Summary of 26 February 2015 CBA Roundtable, Q. 6 under General Concepts – Sham.