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CRA denied her extension request under ETA s. 256(3)(b) (providing for an extension to any “date that the Minister may allow” on the grounds that the Guide disclosure was not inaccurate – and none of the other published grounds for taxpayer relief were met. ...

In characterizing the legislative intent of section 142, the Officer chose to follow the express language of section 142 over the broader purpose of the ETA to tax the consumption of goods or services in Canada …. ...

The taxpayer argued inter alia (at para. 30) that as he “came forward with a voluntary disclosure in a timely fashion … it was unreasonable for the [CRA] Delegate to not exercise discretion in waiving the penalties.” ...

. … The officer was not responding to an application for judicial review of the decision, something that had not yet been commenced at the time of the exchanges. ...

. … ...

The Court, in Canadian Council, goes on at paragraph 39 to state “[…] most internal documents that analyse a problem, starting with an initial identification of a problem, then canvassing a range of solutions, and ending with specific recommendations for change, are likely to be caught within paragraph (a) or (b) of subsection 21(1)”. ...

Before granting the compliance order, Pentney J cited (at para. 19) Cameco for the proposition that “the fact that the requests may involve substantial documentation which the taxpayer may view as not proportional to the matter is not a relevant consideration,” and further stated (at para. 29): [T]here is no evidence to suggest that the CRA audit has been launched for any purpose other than to ensure compliance with the ETA, or that the request for information was so wide, extraordinary, or unusual as to give rise to questions about its legitimacy in the context of the audit (assuming that such a claim could be brought, in the face of the wide authority granted to the Minister to set the timing, scope, and nature of the audit …). ...

After having noted (at para. 15) that the word “document” (used in s. 288(1)), was effectively defined in ETA s. 123(1) to include “any other thing containing information, whether in writing or in any other form ” (her emphasis), she also rejected (at para. 22) the contention of Tellza that “the request for records in an electronically readable format, along with the system administrator’s user ID and password, where applicable, falls outside the scope of the inspection power in the ETA s 288(1).” ...

It may well be the case … that the error in the tax remittances was not made by the CRA or alternatively …that the Applicants could have filed the NR Returns before the filing deadline. ...

. … Words and Phrases income from property ...