R. v. BT Céramiques Inc., 2017 QCCS 4262, rev'd 2020 QCCA 402

In March 2006, an official in the Montreal office of the CRA Special Investigations Division received a tip that a company (BT Céramiques) and...

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Jarvis found that where the predominant purpose of a particular inquiry is the determination of a penal liability (e.g., under s. 239 of the ITA),...

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