Extraordinary cooperation with authorities — including providing access to encrypted records, giving extensive witness statements, testifying in court, and accepting personal danger and harsh protective custody conditions — can justify a sentence that would otherwise appear manifestly inadequate for large-scale tax fraud. A sentence of 2 years' imprisonment (with 12 months before release eligibility) for 210 counts of tax fraud involving $1.28 million in claims and $500,000 in actual losses was upheld on Crown appeal.
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