Section 231.2

Cases

Deloitte & Touche Inc., Trustee of Vancouver Trademark Inc. v. Attorney General of Canada, 97 DTC 5520 (FCTD)

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AGT Ltd. v. Attorney General of Canada, 97 DTC 5189 (F.C.T.A.)

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R. v. Harris, 95 DTC 5653 (BCSC)

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 8 SI demand was criminal 93

Andison v. The Queen, 95 DTC 5058 (FCTD)

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1013808 Ontario Inc. v. The Queen, 94 DTC 6352 (Ont. Ct. (G.D.))

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Montreal Aluminium Processing Ltd. v. Attorney General of Canada, 92 DTC 6567 (FCA)

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Morena v. The Queen, 90 DTC 6685 (FCTD)

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Licht v. MNR, 90 DTC 6574 (FCTD)

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N.M. Skalbania Ltd. v. R., 89 DTC 5495 (B.C. Co.Ct.)

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R. v. McKinlay Transport Ltd., 87 DTC 5051, [1988] 1 CTC 421 (Ont HC), aff'd 88 DTC 6314, [1988] 1 CTC 426 (Ont CA), further, aff'd 90 DTC 6243, [1990] 1 S.C.R. 627

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R. v. Schacher, 86 DTC 6580 (Alta. Prov. Ct.)

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R. v. Bruyneel, 86 DTC 6119, [1986] 1 CTC 295 (BCCA)

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Joseph v. M.N.R., 85 DTC 5391, [1985] 2 CTC 164 (S.C.O.)

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Special Risks Holdings Inc. v. The Queen, 84 DTC 6054, [1984] CTC 71 (FCTD), aff'd 84 DTC 6215, [1984] CTC 563 (FCA)

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Federal - Federal Court Rules - Rule 483(4) 81
Tax Topics - General Concepts - Abuse of Process extremely late motion for further discovery 81

James Richardson & Sons v. M.N.R., 84 DTC 6325, [1984] CTC 345, [1984] 1 S.C.R. 614

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MNR v. Potereyko, 83 DTC 5113 (Sask. PC)

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Words and Phrases
forthwith

In re James Richardson & Sons, Ltd., 82 DTC 6211 (FCA)

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James Richardson & Sons, Ltd. v. MNR, 82 DTC 6204, [1982] CTC 239 (FCA), rev'd supra.

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R. v. Rockville Holding Ltd., 78 DTC 6494 (Alta. S.C.)

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Canadian Bank of Commerce v. Attorney General of Canada, 62 DTC 1236, [1962] S.C.R. 729

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See Also

New Zealand Stock Exchange v. Inland Revenue Commissioner, [1991] 4 All E.R. 443 (PC)

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Administrative Policy

91 C.R. - Q.59

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90 C.R. - Q62

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 231.1 - Subsection 231.1(1) 27

Articles

Kellough, "Section 231.2 Requirement Letters", 1993 Conference Report, pp. 2:1 - 11.

Kroft, "Disclosure to and by Revenue Canada", 1991 British Columbia Tax Conference, Volume 1

Subsection 231.2(1) - Requirement to provide documents or information

Cases

Bauer v. Canada, 2018 FCA 62

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 8 SI investigation did not preclude issuing s. 231.2 requirement 202

Canada (Attorney General) v. Chambre des notaires du Québec, 2016 SCC 20, [2016] 1 S.C.R. 336

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 8 s.231.2 demands for information do not apply to lawyers 370
Tax Topics - Income Tax Act - Section 232 - Subsection 232(1) - Solicitor-Client Privilege exception for accounting records is unconstituional 134

Canada (National Revenue) v. Lee, 2016 FCA 53

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R. v. Logan, 2012 DTC 5155 [at 7381], 2012 BCSC 1444

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Canada (National Revenue) v. Cormark Securities Inc., 2012 DTC 5029 [at 6672], 2011 FC 1472

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Canada (National Revenue) v. Morton, 2007 DTC 5445, 2007 FC 503

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Canada (Minister of National Revenue) v. Ellingson, 2006 DTC 6402, 2006 FCA 202

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Fabi v. Canada (Minister of National Revenue), 2006 DTC 6169, 2004 FC 1779

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Ellingson v. Canada (Minister of National Revenue), 2005 DTC 5492, 2005 FC 1068

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Canada (Customs and Revenue Agency) v. Artistic Ideas Inc., 2005 FCA 68

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Canada (Minister of National Revenue) v. Toronto Dominion Bank, 2005 DTC 5140, 2004 FCA 359

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Les Plastiques Algar (Canada) Ltée v. Canada (Minister of National Revenue), 2004 DTC 6296, 2004 FCA 152

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Canada (National Revenue) v. Kitsch, 2003 DTC 5540, 2003 FCA 307

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Kligman v. MNR, 2003 DTC 5100 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 8 minimal corporate privacy expectation 87

Capital Vision Inc. v. MNR, 2003 DTC 5054 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Onus 64

Pacific Network Services Ltd. v. MNR, 2002 DTC 7585 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Treaties 110
Tax Topics - Treaties - Income Tax Conventions - Article 27 implied power to exercise requirements for information 105

Fraser Milner Casgrain LLP v. MNR, 2002 DTC 7310 (FCTD)

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See Also

Deputy Commissioner of Taxation v Rennie Produce (Aust) Pty Ltd (in liq), [2018] FCAFC 38

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Words and Phrases
Harman obligation
Locations of other summaries Wordcount
Tax Topics - General Concepts - Evidence Revenue free to use documents subject to mooted Harman obligation 137

Brochu v. Agence du revenu du Québec, 2018 QCCS 722

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 8 requirement for information was disguised seizure contrary to s. 8 275

1068754 Alberta Ltd., trustee of DGGMC Bitton Trust v. ARQ, 2018 QCCA 8 (Quebec Court of Appeal)

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Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Territorial Limits communication to bank branch outside Quebec did not constitute a significant act outside Quebec 183

Administrative Policy

19 December 2012 Internal T.I. 2012-0472761I7 - Definition of person in respect to a province

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Articles

Pooja Samtani, "Requirements on the Rise: Defending Against Demands for Taxpayer Information", Tax Management International Journal, 2013, p. 357

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Subsection 231.2(2) - Unnamed persons

Cases

Canada (National Revenue) v. Advantage Credit Union, 2008 DTC 6535, 2008 FC 853

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Articles

Gabrielle St. Halair, amp; Alain-Robert Nadeau, "The Minister's Broad Audit Powers and the Right to Privacy in the Charitable Context", Canadian Current Tax, Vol. 19, No. 9, June 2009.

Subsection 231.2(3) - Judicial authorization

Cases

Canada (National Revenue) v. Hydro-Québec, 2018 CF 622

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 289 - Subsection 289(3) commercial customers of utility were not a group relevant to determining their ETA compliance 272

MNR v. Paypal Canada Co., Docket T-564-17 (FCTD), 10 November 2017

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 289 authorization to demand transaction summaries for the PayPal business account users 115

Rona Inc. v. Canada (National Revenu), 2017 CAF 118

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Canada (National Revenue) v. KPMG LLP, 2016 FC 1322

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Canada (National Revenue) v. Lordco Parts Ltd., 2013 FCA 49

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Canada (National Revenue) v. Greater Montréal Real Estate Board, 2008 DTC 6420, 2007 FCA 346

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Words and Phrases
identifiable

eBay Canada Limited v. Canada (National Revenue), 2007 DTC 5573, 2007 FC 930

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All Saints Greek Orthodox Church v. Canada (Minister of National Revenue), 2006 DTC 6264, 2006 FC 374

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MNR v. Sand Exploration Ltd., 95 DTC 5358 (FCTD)

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See Also

Derrin Brothers Properties Ltd & Ors, R (on the application of) v A Judge of the First Tier Tribunal (Tax Chamber) & Ors, [2016] BTC 10, [2016] EWCA Civ 15

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Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 27 documentary demands made by HMRC pursuant to Art. 27 on UK companies being investigated by Australia were valid 145

Subsection 231.2(6)

Cases

Canada (National Revenue) v. RBC Life Insurance Company, 2013 FCA 50

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Abuse of Process statutory scope of judicial discretion 289