Campbell – Federal Court discloses that a foreign bank consented to provide information respecting foreign transactions of Canadian residents pursuant to a CRA requirement

The taxpayer sought to add a copy of the record in a different court file to the record in his own case, in which he had applied to have a requirement issued to him under s. 231.1(1) set aside on the basis that it was issued as part of a criminal investigation of him. Before denying this request, Grammond J indicated that the other file entailed:

… an application for leave to impose a requirement on Citibank [NA] to disclose information regarding transactions involving Cayman National Bank and unnamed residents of Canada. It was granted on consent. … [I]nformation provided by Citibank as a result of this requirement brought Mr. Campbell’s situation to the attention of the CRA.

Neal Armstrong. Summary of Campbell v. Canada (Attorney General), 2018 FC 412 under s. 231.1(1).