An agency relationship is a common and very practical legal structure within many corporate groups, particularly in the resource industry. In 2015-0576281I7 (recently released), the CRA was refreshingly clear when it rightly said “…the CRA cannot ignore legally valid documents entered into by parties to a transaction and the legal rights that they create in order to assess the tax consequences of such transactions” (citing Shell Canada Ltd. v. The Queen, [1999] 3 S.C.R. 622, at paragraph 39).