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Before finding that the Minister’s decision to reject was reasonable (which relevantly was all that was required), Walker J stated (at para. 107): I have considered the Bank’s … argument that the Minister must approve a proposed methodology if it is fair and reasonable. ...

After having indicated (at para. 23) that the reasonableness of the letters turned on a test of whether there may be considered to be “a rational connection … between the information sought and the administration and enforcement of the ITA,” Fothergill J rejected a submission that the request letters sought foreign-based information and that they should have been issued under s. 231.6, stating (at paras. 37, 43): I am satisfied that Dr. ...

The taxpayer claimed that it was only from a December 2020 phone call with CRA that he learned that CRA considered that he had made an excess contribution in 2012. ...

In denying the applications, the CRA delegate recognized BANA and EY as highly sophisticated entities and considered that a high degree of care and diligence was to be expected, and that this had not been demonstrated by merely accepting a statement from a departing employee that the adjusted tax credit amount was not greater than $500,000 in 2017 when the ITCs claimed for 2017 were in excess of this amount, yet no analysis had been performed in this regard. ...

Southcott J stated (at para. 19) that he found “compelling the Applicants’ position... that CRA appears to have considered the relevant statutory authority to have been sufficient to authorize a reassessment of Strike’s income tax return for the 2017 taxation year (a year in which the Applicants submit the reassessment was favourable to CRA).“ ...

However, KIK’s representatives (KPMG) immediately contacted the officer by email for an explanation and made submissions, and as part of further email exchanges the officer clarified that the items were not considered “same condition” as they were not exported in the same condition as imported since by filling the containers with a substance, a new product was created. ...

., accepted as having been validly and timely filed in April 2016) and that CRA would be withdrawing the certificate and writ for both applicants “as the debt is now considered to be certified in error.” ...

After noting that the reasonableness of the letters turned on a test of whether there may be considered to be “a rational connection … between the information sought and the administration and enforcement of the ITA” (para. 23), Fothergill J stated (at paras. 27, 37): [A]ssessing or re-assessing a taxpayer, even for years that fall outside the normal reassessment period, in circumstances where the taxpayer may have made any misrepresentation attributable to neglect, carelessness or willful default … is a purpose for which a request for information may be made under s 231.1 …. … I am satisfied that Dr. ...

Although the spreadsheet had some aspects of a tax accrual working paper (“TAWP”) considered in BP, there the “FCA’s caution was against imposing an obligation to self-audit” (para. 153), whereas here “[u]nlike BP, the concerns arising from the tax year under audit have not been addressed … [and] the Minister has not sought access to the MSPM (whether or not it is a TAWP) without advancing a particular justification” (para. 152). ...