Section 231.6

Subsection 231.6(1)

Administrative Policy

88 C.R. - "Confidentiality of Taxpayer Information" - "Foreign Based Information Documents"

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Subsection 231.6(2) - Requirement to provide foreign-based information

Cases

Canada (Attorney General) v. Chad, 2018 FC 319

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Locations of other summaries Wordcount
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 423
Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Paragraph 2(b) sun light priciple applied to require review of CRA redactions 303

Merko v. MNR, 90 DTC 6643 (FCTD)

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Administrative Policy

89 C.R. - Q.27

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Articles

David H. Sohmer, "The IRS and CRA vs UBS: Will disclosures be voluntary", The Canadian Taxpayer, Vol. XXXI, No. 1, January 1, 2009, p. 1.

Subsection 231.6(5) - Powers on review

Cases

Soft-Moc Inc. v. Canada (National Revenue), 2013 DTC 5096 [at 5879], 2013 FC 291, briefly aff'd 2014 DTC 5025 [at 6659], 2014 FCA 10

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Fidelity Investments Canada Ltd. v. Canada (Canada Revenue Agency), 2006 DTC 6360, 2006 FC 551

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Saipem Luxembourg S.A. v. Canada (Customs and Revenue Agency), 2005 DTC 5348, 2005 FCA 218

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European Marine Contractors Ltd. v. Canada (Customs and Revenue Agency), 2004 DTC 6070, 2004 FC 114

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Subsection 231.6(8) - Consequence of failure

Cases

Glaxo Smithkline Inc. v. The Queen, 2003 DTC 918 (TCC)

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