Section 231.7

Subsection 231.7(1) - Compliance order

Cases

Canada (National Revenue) v. Lin, 2019 FC 646

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 231.1 - Subsection 231.1(1) - Paragraph 231.1(1)(a) low threshold of relevance - but auditees must be specified 152

Canada (National Revenue) v. Atlas Tube Canada ULC, 2018 FC 1086

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 231.1 - Subsection 231.1(1) required disclosure of an EY tax due diligence report discussing uncertain tax filing positions of a target 343
Tax Topics - Income Tax Act - Section 232 - Subsection 232(1) - Solicitor-Client Privilege predominant purpose of due diligence report was to aid a business decision 307

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

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 231.1 - Subsection 231.1(1) a taxpayer with an unreported Swiss bank account was not yet under criminal investigation 402
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

Revcon Oilfield Constructions Incorporated v. Canada (National Revenue), 2017 FCA 22

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 8 s. 231.7 read down, not invalidated, by Thompson/Chambre des notaires 46

MNR v. SML Operations (Canada) Ltd., 2003 DTC 5535 (FCTD)

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Subsection 231.7(4)

Cases

Canada (Revenu national) v. Les DĂ©veloppements BĂ©arence Inc., 2019 CF 22

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 231.2 - Subsection 231.2(1) no obligation to reformat previously-provided information 140
Tax Topics - Excise Tax Act - Section 289 - Subsection 289(1) no requirement to provide information in reformatted form 109

Canada (National Revenue) v. Chi, 2018 FC 897

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