RE:RE:RE:RE:RE:Re: CRAI think it's actually an important distinction to make. The CRA seems to be making an appeal to what is "fair" rather than what is tax law. During the inital tax trial the CRA referenced OECD guidelines rather than Canadian law. The judge ruled emphatically in Cameco's favor because they were following Canadian tax code and essentially chided the CRA for attempting to apply guidelines that had no basis in Canadian law.