RBC Life Insurance, Lordco - the Federal Court has inherent jurisdiction to go beyond the specific words of the information demand provisions

The Federal Court authorized the Minister to issue demands to some insurance companies to provide the lists of their customers who had purchased a tax product - and later reversed the authorizations when it emerged that the Minister's initial application had failed to disclose that CRA thought the product technically worked but nonetheless was planning an "audit blitz" of the product in order to discourage it.

In upholding the cancellation of the authorizations,  Stratas J.A. indicated that the Federal Court had inherent jurisdiction to control abuse of process and that this included the power to reverse an authorization even where the information omitted by the Minister was not information listed in the applicable statutory provision (s. 231.2(3)) as being relevant - e.g., the motivation of CRA in deciding to initiate audits, or the level of "inconvenience and cost" to the recipients of the demands.

Scott Armstrong.  Summary of MNR v. RBC Life Insurance Company, 2013 FCA 50 under s. 231.2(6).  See also summary of companion case MNR v. Lordco Parts Ltd., 2013 FCA 49,  under s. 231.2(3).