Cases
MNR v. Paypal Canada Co., Docket T-564-17 (FCTD), 10 November 2017
Gascon J granted an authorization for CRA to issue a requirement under ITA s. 231.2 and ETA s. 289 on Paypal Canada to disclose the names and...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 231.2 - Subsection 231.2(3) | all Paypal business account dollar volumes and names required to be disclosed | 212 |
Piersanti v. Canada, 2014 FCA 243
The taxpayer had been convicted of over 30 GST-related offences. In the course of appealing the related reassessments, she moved, on Charter...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 8 | propriety of evidence collection for criminal purposes is irrelevant to its admissibility in tax appeals | 173 |
| Tax Topics - Income Tax Act - Section 231.1 - Subsection 231.1(1) | propriety of evidence collection for criminal purposes is irrelevant to its admissibility in tax appeals | 173 |
Subsection 289(1)
Cases
Canada (Minister of National Revenue) v. Les Développements Béarence Inc., 2019 FC 22
The taxpayer (Béarence) had failed to comply with an order of the Federal Court requiring it to provide, within five days, an Excel file...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 231.7 - Subsection 231.7(4) | CRA cannot require a taxpayer to reformat its information for CRA’s reading convenience | 312 |
| Tax Topics - Income Tax Act - Section 231.2 - Subsection 231.2(1) | no obligation to reformat previously-provided information | 146 |
See Also
Ghermezian v. Canada (Attorney General), 2020 FC 1137
In relation to five requirements for information (“RFIs”) issued pursuant to ITA s. 231.2(1) to four resident individuals and a corporation,...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 231.2 - Subsection 231.2(1) | boundaries between ss. 231.2 and 231.6/no need to name persons if known, and s. 231.2(3) not engaged where information sought re an unnamed person not being investigated | 661 |
| Tax Topics - Income Tax Act - Section 231.2 - Subsection 231.2(3) | no need to name persons if known, and s. 231.2(3) not engaged where the unnamed person are not investigated | 113 |
Subsection 289(3)
Cases
Roofmart Ontario Inc. v. Canada (National Revenue), 2020 FCA 85
Roofmart, a large supplier of roofing materials to residential and commercial contractors in Ontario, unsuccessfully appealed the Federal...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 231.2 - Subsection 231.2(3) | signing of application by Crown counsel was sufficient to establish that it was brought by the Minister | 298 |
| Tax Topics - Income Tax Act - Section 231.2 - Subsection 231.2(3) - Paragraph 231.2(3)(a) | Hydro-Québec regarding limitations on unnamed person requirements (UPRs) “ought not to be followed” | 498 |
Canada (National Revenue) v. Roofmart Ontario Inc., 2019 FC 506, aff'd 2020 FCA 85
Campbell J authorized a requirement by the Minister for Roofmart to disclose the particulars of all its customers who in any of the past 4 ½...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 231.2 - Subsection 231.2(3) | authorization of CRA requirement for a construction material company to disclose its customers with significant purchases | 253 |
Canada (National Revenue) v. Hydro-Québec, 2018 CF 622
The Minister sought judicial authorization under ITA s. 231.2(3) and ETA s. 289(3) for making a demand of Hydro-Quebec to furnish listed...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 231.2 - Subsection 231.2(3) | Hydro-Quebec not required to furnish information on its commercial customers | 431 |