CRA has been reinvigorated in alleging “sham”

A book was recently published discussing the sham doctrine in the English-speaking world, with a focus on tax. In the chapter written by Loutzenhiser on the Canadian cases, he suggests that Stubart and Faraggi indicate that a "sham" can be created by a taxpayer unilaterally, i.e., without a common intention with another to deceive, and then states that Antle:

appears to be intended to 'lower the bar' and make it easier for a court to find a sham exists, possibly by signalling to judges that they should not be unduly troubled about the level of proof required to establish the necessary deceit. In fact, there is some anecdotal evidence that the CRA has begun to issue more assessments alleging sham since Antle.

Neal Armstrong. Summary of Glen Loutzenhiser, "Sham in the Canadian Courts," Sham Transactions (Edwin Simpson and Miranda Stewart, editors), Oxford University Press, 2014 under General Concepts - Sham.