Proposed s. 152(9) might not alter the outcome in Last

Finance responded to the finding in Last, that the prohibition of an increased assessment on appeal is to be applied on a source-by-source basis, by proposing to amend s. 152(9) to provide that additional arguments can be advanced to support "all or any portion of the total amount determined on assessment." “However, it is worth considering whether [this] selected method to address Last would alter the outcome of the decision,” given that this language does not engage with the source-by-source finding in Last.

Neal Armstrong. Summary of Derrick Hosanna, "Alternative Arguments on Appeal: Does Finance Get the Last Word?", Tax For The Owner Manager, Vol. 16, No. 4, October 2016, p. 3 under s. 152(9).