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The information is required to verify the compliance of the taxpayer being audited and no application for judicial authorization is required …. ...

Before remitting the adverse decision of the CRA review officer for decision by another officer, Southcott J noted that the CRA position- that the taxpayer had not made a reasonable error (the first element of s. 204.1(4)) given that the taxpayer was notified of his contribution on a sufficiently timely basis that he could have gone back to RBC to correct its reporting of the contribution while it still had sufficient records of the transaction – was not supported by the record, which did not establish that CRA had notified the taxpayer of his alleged over-contribution in 2013 before December 2020. ...

Canada (Attorney General), 2023 FC 1496-- summary under Subparagraph 141.02(19)(b)(ii) Summary Under Tax Topics- Excise Tax Act- Section 141.02- Subsection 141.02(19)- Paragraph 141.02(19)(b)- Subparagraph 141.02(19)(b)(ii) it was fair and reasonable for CRA to deny relief from a mistake attributed to outsourcing all of a tax department The appellant (“BANA”), a Canadian subsidiary of Bank of America Corporation, reduced its Canadian tax department from four to one employee in 2018 as it entered into a tax outsourcing arrangement with Ernst & Young (EY). ...

The only response was a call from a CRA complaints officer on January 18, 2024 advising that the Minister’s office would be responding to the two letters – which did not occur. ...

After this granting of an earlier effective registration date, 353 then refiled the returns for the initial three quarters, and CRA then promptly assessed 353’s returns – but apparently not the initial three quarters. ...

. … I believe it was reasonable for the Minister’s Delegate to conclude that a CRA agent would seek to follow up with the Applicant regarding its obviously missing T1135 return.” ...

Accordingly, the plaintiffs had not met the first requirement for a mandamus order (the existence of a legal obligation of a public character) – nor had they demonstrated that the Minister’s decision was unreasonable. ...

The Minister is under a statutory duty to determine the tax that is owing or a refund is due in relation to the August 2018 return of the Applicant, pursuant to section 275 …. ...

It was not improper for CRA to forward to the Swiss authorities a copy of a decision from the Quebec Tribunal administratif des marchés financiers (which CRA had obtained from the AMF) that reproduced allegations raised by the AMF, notably regarding the potential existence of two bank accounts in Switzerland, as CRA had not presented “mere suspicions as facts” and, as it had been provided to them in full, “the Swiss authorities … could appreciate the nature and reliability of the allegations [therein]” (para. 115). ...

This registration-date issue was not resolved until over three months later, when CRA changed the effective date of the registration to August 1, 2012. 353 then refiled the returns for those earlier reporting periods during which it previously had not been registered, and on November 7, 2017, CRA assessed 353’s returns – but apparently not the initial three quarters. ...