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., 2020 FC 1044-- summary under Subsection 289.1(3) Summary Under Tax Topics- Excise Tax Act- Section 289.1- Subsection 289.1(3) refused addition to a disclosure compliance order of a condition that CRA give notice before disclosing the information to another authority The Minister sought a compliance order under s. 289.1(1) to compel the respondent (“EEIGI”) to provide certain access, assistance, information and documentation sought by the Minister in connection with an audit (the “Required Information”). ...

In December 2003, in connection with a number of fish harvesters, the CRA offered to treat half of their [licence retirement program] payments as non-taxable, and the other half as capital gains. ...

However, this was essentially irrelevant to the point that the implied waivers nonetheless had been given (albeit, in connection with objecting to reassessments that were replaced by, and, therefore, voided by, the second reassessments.) ...

Both were now Canadian citizens, and neither one has any real ongoing connection with the U.S. ...

She stated that she filed late because she was away from Fredericton from February to May 2016, and did not have the necessary documents to file on time, and in connection with the second-level review (where her application was also rejected), noted her reliance on her telephone call. ...

In order to expedite and facilitate our audit, we will require a clear understanding of all entities with which you had a connection or affiliation during the taxation years noted above. … Please send us back the attached questionnaire fully completed within 30 days …. ...

As to the Applicant's argument that the missing information was already filed with CRA in connection with its 2013 SR&ED claim and should have been utilized for purposes of its 2012 claim… [i]t is significant that Form T661 specifically requests information in relation to only the one tax year for which the SR&ED claim is made. ...

Chad, 2018 FC 319-- summary under Section 37 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Canada Evidence Act- Section 37 CRA had to show and justify why it had to redact materials in order to not shed light on its audit methodology In connection with an application by the taxpayer (the Respondent) to have requirements issued to it by the Minister pursuant to ss. 231.1 and 231.6 set aside on the basis that they were invalid or overly broad, he requested, pursuant to Rules 317 and 318 of the Federal Courts Rules, all material relied on to issue the Requirements. ...

In granting the order and rejecting the taxpayer’s submission that the request letters were issued in connection with “a criminal investigation going on behind the scenes of which the [CRA] Auditor ha[d] no knowledge,” Russell J stated (at paras 50, 55, 58 and 59): … Offshore accounts are not, per se, illegal and it is the duty of the Minister under the Act to inquire and ensure that those with offshore accounts are meeting their tax liabilities. … If the Respondent’s position were accepted, it would mean that, given the government’s intent to deal with offshore tax offenders, every Canadian taxpayer with an offshore bank account would be immune from compliance with the audit requests made under s 231.1(1) because this could lead to criminal proceedings at some time in the future. ...

Both were now Canadian citizens, and neither one has any real ongoing connection with the U.S. ...