Section 231.1

Subsection 231.1(1) - Inspections

Cases

Canada (National Revenue) v. Stankovic, 2018 FC 462

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 7 use of stolen data provided by French tax authorities did not violate taxpayer's Charter rights 182
Tax Topics - General Concepts - Stare Decisis Quebec CA decision relied upon 32
Tax Topics - Income Tax Act - Section 231.7 - Subsection 231.7(1) mere suspicion of criminal activity did not oust s. 231.1 188

Campbell v. Canada (Attorney General), 2018 FC 412

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Canada (National Revenue) v. BP Canada Energy Company, 2015 DTC 5077 [at 5958], 2015 FC 714

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Piersanti v. Canada, 2014 FCA 243

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 8 propriety of evidence collection for criminal purposes is irrelevant to its admissibility in tax appeals 151
Tax Topics - Excise Tax Act - Section 289 propriety of evidence collection for criminal purposes is irrelevant to its admissibility in tax appeals 151

R. v. Posteraro, 2014 DTC 5040 [at 6734], 2014 BCPC 31

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R v. He, 2012 DTC 5129 [at 7234], 2012 BCCA 318

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 288 - Subsection 288(1) 169

Redeemer Foundation v. Canada (National Revenue), 2008 DTC 6474, 2008 SCC 46, [2008] 2 S.C.R. 643

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Stanfield v. Canada (Minister of National Revenue), 2005 DTC 5454, 2005 FC 1010

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R. v. Dial Drugstores Ltd., 2003 DTC 5206 (Ont. Sup. Ct. J.)

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R. v. Ling, 2002 DTC 7566, 2002 SCC 74, [2002] 3 S.C.R. 814

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R. v. Jarvis, 2002 DTC 7547, 2002 SCC 73, [2002] 3 S.C.R. 757

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Words and Phrases
enforcement

The Queen v. Norwood, 2001 DTC 5111 (FCA)

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 8 surreptitious photocopying 162

The Queen v. Kloster, 98 DTC 6258 (Prov. Ct. B.C.)

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 8 taking of bank records breached privacy 50

The Queen v. Norway Insulation Inc., 95 DTC 5328 (Ont. C.J. (G.D.))

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R. v. Rosenberg, 87 DTC 5189, [1987] 1 CTC 385 (S.C.O.)

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Lipsey v. MNR, 84 DTC 6192, [1984] CTC 208 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Evidence 46

See Also

R. v. BT Céramiques Inc., 2017 QCCS 4262

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 8 mere suspicion of tax evasion and corrupting CRA officials is insufficient to invalidate audit information 521

R v. Lombardo, 2011 DTC 5065 [at 5733] (B.C. Prov. Ct.)

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Mommersteeg and Giffen v. The Queen, 96 DTC 1011 (TCC)

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O'Reilly v. Commissioners of the State Bank of Victoria (No.2), 83 ATC 4156 (HC)

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Administrative Policy

24 May 2018 CTF Seminar - Preventing, Navigating, and Resolving Tax Disputes under “Managing Tax Risk, The Ins and Outs of Reporting and Compliance” (Gordon Parr)

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23 February 2016 Toronto Centre Tax Professionals Seminar under “Access to Accountants' Working Papers”

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90 C.R. - Q62

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 231.2 47

86 C.R. - Q.29

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81 C.R. - Q10

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79 C.R. - Q34

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Paragraph 231.1(1)(d)

Cases

Canada (National Revenue) v. Cameco Corporation, 2017 FC 763

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Rules (General Procedure) - Section 95 - Subsection 95(1) unfettered CRA interview right would undercut Rules and proportionality principle 250
Tax Topics - Statutory Interpretation - Redundancy/reading in words presumption against tautology 44

BP Canada Energy Company v. Canada (National Revenue), 2017 FCA 61

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Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Interpretation Act - Section 8.1 federal power should be exercised harmoniously with provincial law 202

Administrative Policy

20 November 2017 CTF Annual Conference - CRA Panel on Issues in the Administration and Enforcement of the ITA, Q.12

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20 November 2017 CTF Annual Conference - CRA Panel on Issues in the Administration and Enforcement of the ITA, Q.11

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Subsection 233.1(2)

Administrative Policy

7 October 2016 APFF Roundtable Q. 1C, 2016-0652771C6 F - T106 and multiple year ends

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Subsection 231.1(3) - Application

Cases

R. v. Baudais, 2014 DTC 5071 [at 6973], 2014 BCSC 856

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Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Other/Conflicting Statutes CRA could obtain warrants under Criminal Code rather than tax statutes 96

A.G. (Canada) v. Pica, 86 DTC 6001, [1986] 1 CTC 155 (Ont CA)

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The Queen v. Dzagic, 85 DTC 5252, [1985] 1 CTC 346 (S.C.O.), rev'd 86 DTC 6432, [1986] 2 CTC 288 (Ont CA)

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New Garden Restaurant and Tavern Ltd. v. MNR, 83 DTC 5338, [1983] CTC 332 (SCO)

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Royal Craft Products Ltd. v. The Queen, 80 DTC 6143, [1980] CTC 97 (Alta. C.A.)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 231.3 - Subsection 231.3(3) 46

In re Usarco Ltd., 80 DTC 6085, [1980] CTC 145 (Ont CA)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 231.3 - Subsection 231.3(7) 108

Subsection 231.1(4)

See Also

Delzotto v. The Queen, 95 DTC 5518 (FCTD)

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