Développements Béarence – Federal Court finds that CRA cannot require a taxpayer to reformat its information for CRA’s reading convenience

Grammond J had previously made an order pursuant to s. 231.2 that the taxpayer (“Béarence,” a land developer with numerous land sales and who had been undergoing a CRA audit) provide, within five days, an Excel file containing all the daily transactions for its 2012 to 2015 years and a report of transactions by each general ledger account for those years. In finding that Béarence could not now be found to be in contempt of court for not having provided these documents, Bell J accepted Béarence’s submission that CRA already had all the information it needed to perform its audit and stated):

[N]either the CRA nor this Court can impose the format in which this information must be provided to the CRA, as all the necessary information has already been provided.

Neal Armstrong. Summary of Canada (Revenu national) v. Les Développements Béarence Inc., 2019 CF 22 under s. 231.7(4).