CRA positions on plain vanilla domestic structures may not be portable to offshore structures
A response co-authored by Len Lubbers stated:
[W]here reliance is placed on a published view regarding a plain vanilla domestic tax arrangement, taxpayers should not be surprised that the CRA might take the view that the underlying facts and issues in an offshore structure would be sufficiently distinguishable to result in a challenge to taxpayer’s self-reported assessment of tax. …
The response also referenced CRA’s “commitment … to resolve disputes at the earliest possible stage.”
Neal Armstrong. Summary of 27 November 2018 CTF Roundtable Q. 7, 2018-0779951C6 under s. 152(1).