These days, in so many aspects of our lives, we are the product (as the saying goes). Retailers, for example, offer loyalty programs because, among other things, they allow our spending habits to be tracked. It turns out that the retailers aren’t the only entities interested in our spending habits, however. The CRA could use these programs to determine whether we have unreported income (eg by obtaining information about our cash purchases from a retailer). See Steven Raphael and Robert G. Kreklewetz, “Loyalty Program Data May Assist the CRA” 25:10 Canadian Tax Highlights (October 2017), which discusses Rona Inc. c Canada (Revenu national), 2017 CAF 118.
Neal Armstrong reports that the Federal Court has ruled that an agreement concluded by one auditor not to further audit a taxpayer is binding on the CRA. See Rosenberg v MNR, 2016 FC 1376. I have not been able to find the decision online yet.
What are the odds that an auditor will enter into another one of these agreements?