The waiver of the rights of objection (the waiver) is a condition of the validity of the review agreement and must accompany or contain any such agreement. The waiver is a declaration signed voluntarily by a subject or agent, in which the subject renounces both the right to object to one or more issues outlined in the review agreement and in the waiver and appeal. In particular, Section 165, paragraph 1.2, of the Income Tax Act (ITA) and Section 301, paragraph 1.6, of the Excise Act (ETA) limit a taxpayer to raise objections to the assessment of an issue for which the right of objection has been waived in writing. In addition, Article 169, paragraph 2 of the ITA and Article 306, paragraph 2 of ETA prevent the subject from appealing the assessment of an issue for which the right of objection or appeal has been annulled in writing. Footnote 5 These rules are corroborated by De SmerchanskiFootnote 6, which confirms the proposition that the right to appeal an assessment is a private right that can be waived. Note that this does not apply to international transactions. A taxpayer cannot relinquish his rights to the contract. In certain circumstances, it may be appropriate to apply an audit agreement and a waiver to deal with international issues. Since the exceptions cannot extend contractual deadlines and cannot limit the right of the subject to the mutual agreement procedure, they cannot provide assistance in the case of cross-border transactions with a contracting state in which the treaty provides for a procedure of mutual agreement for the settlement of disputes. At the meeting with the subject and/or representative, the statutory auditor must specify that the positions that can be taken by both parties in obtaining or attempting to obtain an audit agreement apply only to the current assessment on the basis of the facts and information relevant to the situation and therefore cannot be used to find further action. In other words, the terms of the audit agreement are not transferable to future audits or audits of the subject or other similar audit issues.