1. Opportunities to challenge geographical and jurisdictional limits of the existing tax regime. Inter jurisdictional issues are becoming more commonplace. Challenges to the scope of key legislative provisions are also being mounted at an increasing pace. Increasingly, the issues faced by sales tax professionals relate to the limits and boundaries of the existing tax scheme. These issues include the following: does this provision even apply to my situation? How do we resolve conflicting provisions? Does the policy back the technical position? Is the administrative position consistent with the legislation? Could certain interpretations of the legislation result in unjust results? Should the legislation be changed? How do I apply analogous provisions?
2. Opportunities to rely upon non-tax resources to assist in the resolution of substantive tax issues. Principals extracted from other areas of law such as administrative law, constitutional law or contract law provide the foundation upon which many issues are resolved.
3. Opportunities to find relief based upon procedural strategies. Many of the procedural relief provisions are not even contained in the tax legislation. For example, the common law principal enunciated in the criminal case of Sault Ste Marie v. the Queen can provide a defence to a tax assessment. This and many other procedural defences have not yet been fully explored.
4. Opportunities to use existing jurisprudential and administrative context to resolve issues. A complex regulatory fabric has been woven from administrative policy and an extensive body of case law. New issues are increasingly being resolved not just by direct reference to this existing body of knowledge, but also by analogy. Use of existing jurisprudential and administrative resources is a powerful tool both for advancing positions and for identifying whether positions are correct.
5. Opportunities to be better informed as to government policies. Government bodies are increasingly flexible to providing access to their positions both orally and in writing. This new level of transparency is particularly effective for taxpayers in meeting their compliance objectives. 
