Section 231.7


BMO Nesbitt Burns inc. v. Canada (National Revenue), 2023 FCA 43

an intervening reassessment did not justify a failure to produce requested information

The Federal Court had granted a CRA application pursuant to s. 231.7 seeking an order requiring BMO Nesbit Burns (“NBI”) to provide an unredacted version of a spreadsheet in connection with CRA’s audit of suspected dividend rental arrangement transactions of NBI. Locke JA found no reversible error in the findings below that NBI had not established that the redactions were necessary to protect legal advice from disclosure.

In rejecting NBI’s further argument (at para. 7) that “the Minister’s application should not have been granted in the absence of an ongoing tax audit,” Locke JA stated (at para. 7) that “there is no doubt that the audit was ongoing when the Minister first requested the unredacted Spreadsheet,” and further stated:

[I]t cannot have been Parliament’s intent to permit the target of an audit to avoid an order pursuant to subsection 231.7(1) of the Act by delaying compliance with a document request until after issuance of a notice of reassessment. …

To conclude otherwise would reward non-compliance with legitimate document requests from the Minister.

In briefly rejecting NBI’s submission (at para. 8) “that ordering production of the unredacted Spreadsheet amounts to requiring NBI to conduct a self-audit or to reveal its ‘soft spots’,” he stated that “we find that the decision of this Court in BP Canada … is distinguishable.”

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 232 - Subsection 232(1) - Solicitor-Client Privilege providing a full spreadsheet would not breach privilege 205

Subsection 231.7(1) - Compliance order


Canada (National Revenue) v. BMO Nesbitt Burns Inc., 2022 FC 157, aff'd 2023 FCA 43

providing a full spreadsheet would not breach a requirement not to disclose uncertain tax positions, and could be enforced after a TCC appeal

The Minister brought an application pursuant to s. 231.7 seeking an order requiring the respondent (“BMONB”) to provide an unredacted version of a spreadsheet (the “MSPM”). The redacted column in the spreadsheet, which had been provided by BMONB pursuant to a request made by CRA in July 2019 in relation to its audit of suspected dividend rental arrangement transactions engaged in by BMONB in its 2016 taxation year, was claimed by BMONB to reflect legal advice in a small portion of legal written advice received by it in 2012 and 2013 from two law firms (McCarthy’s and Torys).

After finding that the MSPM was not protected by solicitor-client privilege, Kane J also rejected some further submissions of the taxpayer.

Kane J found (at para. 120) that “there are no time limits for the Minister’s exercise of its authorities pursuant to section 231.1 or 231.7, stating (at para. 121) that “[i]f Parliament intended to impose time limits, it could have done so.”

Furthermore, in rejecting the BMONB submission that the Minister was precluded from relying on s. 231.1 or 231.7 because there was no open audit or inquiry, she indicated (at para. 126) that she did “not agree that BMONB’s notice of objection puts an end to the Minister’s authority pursuant to sections 231.1 or 231.7,” noting that “[i]n the present case, the Minister made the request for information pursuant to section 231.1 in 2019, long before the reassessment or notice of objection, and stated (at para. 127):

[R]estricting a request for information to the pre‑assessment or pre-reassessment period would not be in the spirit of the Act, which gives broad powers to ensure the administration and enforcement of the Act, and could promote non‑compliance.

In addition, BP “did not refuse to order compliance with the Minister’s request for information solely because the audit for a specific year had concluded, but because the information had been requested for broader purposes, other than the issues identified in the audit, and the issues identified in the audit had already been addressed,” whereas here, “the Minister identified the specific purpose of the Request for Information related to the 2016 audit … [which] information has not been provided and the issue identified in the audit has not been resolved” (paras. 129, 131).

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).

Finally, regarding a submission that granting the requested production would undermine the discovery process in the Tax Court of Canada proceedings, which had procedural protections not set out in s. 231.1, Kane J stated (at para. 160) that Cameco (at paras. 40-41):

…found that the Tax Court of Canada Rules are not a factor in determining the Minister’s powers under section 231.1. The Court of Appeal noted that the Tax Court of Canada could sort out any issues regarding the admissibility of the evidence or potential prejudice arguments.

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Tax Topics - Income Tax Act - Section 232 - Subsection 232(1) - Solicitor-Client Privilege spreadsheet did not communicate the very legal advice given 236

Canada (National Revenue) v. Dominelli, 2022 FC 187

taxpayer’s affidavit did not contain the agreed particulars for complying with document-provision agreement in lieu of s. 231.7 judgment

The taxpayer (“Dominelli”) had entered into two leveraged insurance annuity arrangements for which he had claimed $139 million in carrying charges from his employment income. The Minister had sought a s. 231.7 compliance order for documents respecting Dominelli’s 2016 taxation year. Before the Federal Court rendered a decision on the Minister’s application, Dominelli and the Minister reached an agreement under which Dominelli undertook “to perform a detailed and exhaustive search of… records in my possession” and to “particularize my efforts” and “to request and direct my professional advisors to conduct an exhaustive search”, “to make inquiries of individuals and entities listed below” and to “particularize my efforts in making these inquiries,” all as described by affidavit with appended documents – with it being further agreed that if the Minister was not satisfied with the affidavit materials, she would ask that judgment be delivered on the compliance application. After the Minister indicated that the affidavit response was unsatisfactory, Dominelli brought this motion before Pentney J to enforce the settlement agreement, and Diner J agreed to keep postpone rendering judgment in the compliance application until this motion was decided.

Pentney J stated (at para. 59) that he agreed “with Dominelli that the scope of the Minister’s discretion to determine that she is not satisfied that he has discharged his obligations under the agreement must be limited by the terms of their agreement … .”

However, in going on to find that Dominelli’s affidavit did not demonstrate that he had met his obligations under the agreement, Pentney J stated (at para. 66):

His affidavit contains no information regarding any search of his own records, and no indication that he requested his professional advisors to search for anything. Instead, it simply states that on January 13, 2021, Robert Young [the insurance consultant] sent documents pertaining to the Outstanding Material to his lawyers “that Young advises contains the answers to certain requests made by the applicant in this summary application.” Implicit in this statement is that Dominelli must have asked Mr. Young to conduct some sort of search, but no details are provided.

After noting the various documents that had been requested on audit and not provided, Pentney J stated (at para. 79):

Understood in that context, the gap between what Dominelli promised to do and what his affidavit states is striking. … [H]is evidence does not establish that he has met the specific and detailed terms of the agreement and the Undertaking that he negotiated, and thus his motion cannot succeed.

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Tax Topics - Excise Tax Act - Section 289.1 - Subsection 289.1(1) an agreement to compromise an ITA s. 231.7 compliance procedure would have been binding if complied with by the taxpayer 244

Canada (National Revenue) v. Miller, 2021 FC 851

s. 231.7 compliance order for a description of the terms of an oral contract

Mr. Miller did consulting work for a European client (“Casala”). He also received payment of his professional fees from other clients through deposits in trust with two Canadian law firms.

Walker J granted a compliance order pursuant to s. 231.7(1) regarding an extensive list of items that CRA had demanded including information regarding the terms and conditions of his oral contract with Casala and copies of the trust ledgers from one of the law firms.

Regarding her order to disclose the terms of his oral contract with Casala, she stated (at para. 44) that this was information “that Mr. Miller ought to have documented in his records,” that the “requests do not stray into the problematic type of questions identified in Cameco and BP Canadae.g., an attemptto compel Mr. Miller to reveal his ‘soft spots’,” and that a “request for the information that would have been included in any written contract and issued invoices is the Minister’s mechanism to ensure her access to basic information necessary for the Audit.”

Regarding the required disclosure of the trust ledger accounts with the law firms, she stated (at para. 59):

I do not agree that the Cameco decision establishes that a taxpayer discharges their obligation to satisfy a request that is otherwise within the scope of subsection 231.1(1) with a response that they simply do not have those documents in their possession. … [A] taxpayer is required to exercise reasonable efforts to obtain and provide to the Minister information and documentation that should be in its books and records.

Walker J did not make a compliance order for a description of the development of Mr. Miller’s business relationship with Casala (para. 54).

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 231.1 - Subsection 231.1(1) - Paragraph 231.1(1)(a) taxpayer required to disclose terms of oral contract and to obtain documents that should have been in his records 518

Blue Bridge Trust Company Inc. v. Canada (National Revenue), 2021 FCA 62

Minister obtained compliance order re French request for trust details re French wealth tax

Art. 26(1) of the Canada-France Convention provided for exchanges of “such information as is foreseeably relevant … to the administration or enforcement of the domestic laws concerning taxes of every kind … imposed on behalf of the Contracting States, insofar as the taxation thereunder is not contrary to the Convention.”

CRA issued requests for information (RFIs) to the appellant (“Blue Bridge”), which was the trustee of some trusts, as a result of a request made by the French tax authorities pursuant to Art. 26 for various particulars regarding the trusts, including the identity of the beneficiaries and financial information.

Blue Bridge argued that it was the Minister’s responsibility to ensure that the “taxation … not contrary to the Convention” condition in Art. 26 was met before transmitting the requested information to France, whereas here, France was seeking to impose tax under a French wealth-tax statute which attributed all foreign trust assets to a French settlor or beneficiary in order to subject them to the tax, which in its view raised the possibility of the information being used to levy tax contrary to the Convention.

In rejecting this argument, Rivoalen JA determined that the Federal Court did not have expert evidence of French law so as to be able to conclusively address this argument, and that this argument was based on facts that had not been verified, and could not be verified at this stage, by the Minister. She stated (at para. 47, TaxInterpretations translation):

The judge rightly concluded that a requirement for thorough research and analysis of the facts and the law of the requesting State would impede the proper and effective operation of the Convention’s provisions … .

She concluded that the Federal Court had not erred in finding that the requirements for issuing a compliance order under ITA s. 231.7(1) had been met.

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Tax Topics - Treaties - Income Tax Conventions - Article 27 CRA was not responsible for analyzing whether information requested by France could be used contrary to the French Treaty 350

Canada (National Revenue) v. Friedman, 2019 FC 1583, aff'd 2021 FCA 101

Lin interpretation, that a requirement letter insufficiently specified who was covered, not followed

The Friedmans, a married couple, who had not filed T1135 returns, each received Requests for Information under s. 231.1(1) (“RFIs”) whose wording was essentially identical to those received by the taxpayers in Lin, e.g., they were addressed to them personally, and stated inter alia:

Your personal income tax returns and any other related or associated entities have been selected for audit … . [Y]ou may have offshore holdings that you have failed to disclose … .

In order to expedite and facilitate our audit, we will require a clear understanding of all entities with which you had a connection or affiliation during the taxation years noted above. …

Please send us back the attached questionnaire fully completed within 30 days … .

The taxpayers refused to provide the requested information and argued that, like Lin, the RFIs were not clearly addressed to them and it was unclear whether the CRA is auditing them or their related entities. In rejecting these submissions, Pamel J noted that it was unclear whether the Court in Lin was provided with the questionnaires accompanying the letters, and stated (at para. 35):

Upon close examination of the RFIs and, in particular, the accompanying questionnaires, I am satisfied that, unlike in Chamandy [2014 FC 354] and SML, the CRA is clearly directing its questions to Mr. and Mrs. Friedman in their personal capacity as taxpayers. In addition, as opposed to how matters were assessed in Lin, the CRA is specifically directing those questions to the Friedmans in respect of their personal tax situation.

Pamel J also rejected their submissions that the RFIs contravened s. 13 or 7 of the Charter.

Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 13 s. 231.1(1) demand made in civil audit context did not contravene s. 13 123
Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 7 s. 231.1(1) demand made in civil audit context did not contravene s. 7 172

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

CRA request for an information-request compliance order dismissed because it was unclear which entities were covered

The three respondents were a couple and their daughter. The father considered himself to reside only in China, whereas his wife and daughter acknowledged that they were Canadian residents. The father stated that he had filed Canadian returns only because he did not realize that he was a non-resident.

Each respondent received a letter from CRA in September 2016, captioned as being respecting an audit of the 10 taxation years ending on December 31, 2015, and stating:

Your personal income tax returns and any other related or associated entities have been selected for audit for the above noted period. [CRA] is in possession of information that has led us to determine that you may have offshore holdings that you have failed to disclose as required by the Income Tax Act. All individuals, corporations, trusts or partnerships are required to complete and file form T1135 … .

The letter went on to request completion of a questionnaire. Only some of the information was provided, and CRA then sought a compliance order under s. 231.7.

In rejecting most of the respondents’ submissions, Boswell J stated (at paras. 23, 25 and 27):

[A]ny valid reason, such as a suspicion of offshore holdings, meets the low threshold for the reasonableness of an audit … .

… There is no statutory time limit within which to make a request for information under subsection 231.1(1) … .

The fact that the Letter does not specify the documents, books, or records to be produced is not fatal to the requests for information … .

However, he nonetheless dismissed the application on the following ground (paras.31-32):

[T]he Letters are addressed to both the individuals and their connected entities. The entities are not specified, and it is not clear who is being audited - the individual Respondents or unnamed entities.

The Court must be satisfied that the person against whom a compliance order is sought is one who was required under section 231.1 or 231.2 to provide the access, assistance, information or document sought by the Minister. Because it is not at all clear whether the Letter was directed to the Respondents individually or their connected entities, the first requirement of section 231.7 … for obtaining a compliance order has not been satisfied by the Minister … .

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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 160

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

low threshold of relevance was met

The U.S. parent (JMC) of the Canadian taxpayer (Atlas) acquired another Canadian company (LSI), following which some of the pieces of LSI ended up in Atlas’ hands in a post-closing reorganization. CRA requested, pursuant to s. 231.1, a copy of a tax due diligence report - that EY had prepared on LSI in advance of the LSI acquisition - on the grounds that it might be relevant to its audit of Atlas.

The EY report included an analysis of the tax filing positions taken by LSI and their risk of successful challenge by CRA. Atlas argued that compelling disclosure of the report was contrary to BP, which found that tax accrual working papers setting out uncertain tax positions were protected. In rejecting this argument, Southcott J stated (at paras. 65-66):

BP is to be read as precluding general and unrestricted access to TAWPs on a prospective basis, outside the context of an audit of particular issues. …

… Unlike in BP, the Minister’s request for access to the Report in the present case is made in the context of an active audit of particular issues. …[T]he information in the Report sought by the Minister meets the applicable threshold of relevance in that context. I therefore find that compelling Atlas to provide the Report would not offend the principle described in BP that a taxpayer is not required to self-audit.

He also found that, as the report’s “dominant purpose when commissioned and generated was to inform the decision whether to proceed with the transaction and at what price” rather than to assist Stikeman in structuring the acquisition, it was not protected by solicitor-client privilege.

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 373
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 336

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

mere suspicion of criminal activity did not oust s. 231.1

CRA found out from the French authorities that the taxpayer was on the list obtained from a disgruntled HSBC employee of those with large Swiss bank accounts. The taxpayer had not reported the account or the interest thereon. When CRA sought a compliance order under s. 231.7(1) for the taxpayer to answer its requests for information issued under s. 231.1(1), the taxpayer argued that it was obvious that this was occurring pursuant to a criminal investigation of her. Russell J disagreed, stating (at paras. 50, 55) that:

Offshore accounts are not, per se, illegal and it is the duty of the Minister under the Act to inquire and ensure that those with offshore accounts are meeting their tax liabilities. … If the Respondent’s position were accepted, it would mean that, given the government’s intent to deal with offshore tax offenders, every Canadian taxpayer with an offshore bank account would be immune from compliance with the audit requests made under s 231.1(1) because this could lead to criminal proceedings at some time in the future. …

[A] mere suspicion does not change the predominant purpose of an audit into a criminal investigation. See Jarvis … .

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 436
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 202
Tax Topics - General Concepts - Stare Decisis Quebec CA decision relied upon 40

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

s. 231.7 continues to apply to non-lawyers

The taxpayer was ordered by the Federal Court under s. 231.7 of the Act to comply with certain requests for documents and information issued against it during an audit. In rejecting the taxpayer’s submission, based on Chambre des notaires and Thompson, that the Federal Court lacked authority to make this order, Stratas JA stated (at paras 6 and 7):

[T]he Supreme Court read down section 231.7 to exclude lawyers and notaries. But section 231.7 otherwise remains in force.…

… The appellant is neither a lawyer nor a notary. Therefore, in this case, section 231.7 still authorized the Federal Court to make the order it did.

Respecting the further submission that the order “indirectly ordered the appellant’s law firm to disclose material, contrary to the Supreme Court’s two decisions” he stated (para. 9):

… The Federal Court’s order is directed only against the appellant… . Here, the client had a full opportunity to contest issues relating to legal professional privilege and legal professional privilege was fully respected in this case.

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 60

Canada (Minister of National Revenue) v. SML Operations (Canada) Ltd., 2003 DTC 5535, 2003 FC 868

An application by the Minister was dismissed given that the Minister had not demonstrated that the person served with the requirement letter was the taxpayer rather than its officer in his personal capacity (as the salutation in the requirement letter was addressed "Dear Sir", and a threat of incarceration for failure to respond suggested that the letter was not directed to a corporation), and given that it had not been demonstrated that the person required to provide the requested information or documents had not done so (as there had been the production of some documents).

See Also

Canada (National Revenue) v. 2276230 Ontario Inc., 2021 FC 242

Cameco principles applied in granting compliance order

CRA had requested that three taxpayers provide information (characterized by it as routine business information) pursuant to ETA s. 288(1) (similar to ITA s. 231.2(1)) and when many of the requests were either not answered at all or only partially by the last of the extended deadlines, it sought a compliance order.

Before granting the compliance order, Pentney J cited (at para. 19) Cameco for the proposition that “the fact that the requests may involve substantial documentation which the taxpayer may view as not proportional to the matter is not a relevant consideration,” and further stated (at para. 29):

[T]here is no evidence to suggest that the CRA audit has been launched for any purpose other than to ensure compliance with the ETA, or that the request for information was so wide, extraordinary, or unusual as to give rise to questions about its legitimacy in the context of the audit (assuming that such a claim could be brought, in the face of the wide authority granted to the Minister to set the timing, scope, and nature of the audit …).

Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 289.1 - Subsection 289.1(1) CRA requirement for information need not be demonstrated by it to be proportional to the matter at issue 323

Subsection 231.7(3)

See Also

Canada (National Revenue) v. Edward Enterprise International Group Inc., 2020 FC 1044

no basis established for adding notice requirement to compliance order

The Minister sought a compliance order under ETA s. 289.1(1) (similar to ITA s. 231.7(1)) to compel a Canadian corporation (EEIGI) to provide information needed in an audit. Southcott J rejected EEIGI’s request that the compliance order should include a condition that EEIGI be given notice before any of the information was shared outside the CRA (EEIGI’s principal was involved in foreign criminal proceedings).

Southcott J stated (at paras. 34, 37):

… EEIGI is seeking this relief without having articulated with any precision a basis in either fact or law for its concern that it may in the future face dissemination of the Required Information in a manner that offends the Charter.

… [R]equiring CRA to disclose, in the course of an investigation, the fact that the investigation is taking place could compromise the investigation. EEIGI has identified no precedent or statutory authority for the imposition of such a requirement, other than the general discretion that s 289.1(3) of the ETA affords to the Court to impose, in an order issued under s 289.1(1), any conditions that the Court considers appropriate.

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Tax Topics - Excise Tax Act - Section 289.1 - Subsection 289.1(3) refused addition to a disclosure compliance order of a condition that CRA give notice before disclosing the information to another authority 246

Subsection 231.7(4)


Canada (Minister of National Revenue) v. Les Développements Béarence Inc., 2019 FC 22

CRA cannot require a taxpayer to reformat its information for CRA’s reading convenience

Grammond J had previously made an order pursuant to s. 231.2 that the taxpayer (“Béarence,” a land developer with numerous land sales and who had been undergoing a CRA audit) provide, within five days, an Excel file containing all the daily transactions for its 2012 to 2015 years and a report of transactions by each general ledger account for those years. Over five months later, the Minister sought an order that Béarence was in contempt of court for not having complied with the order.

Bell J accepted the taxpayer’s submission that CRA already had available to it all the information it needed (including with respect to federal and provincial "sales tax" matters - para. 10) to perform its audit (including the provision to it of a copy of the general ledger, and information provided to the ARQ) and stated (at paras. 12-13, TaxInterpretations translation):

[D]oes the CRA have the right to require that Béarence disburse funds to provide information in the format requested by the CRA where this information has already been provided and is available in another format? …

[N]either the CRA nor this Court can impose the format in which this information must be provided to the CRA, as all the necessary information has already been provided.

He went on to find, in the alternative, that in any event, the following elements for a finding of contempt were not established: an unequivocal indication of what must be done (the order appeared to incorrectly assume that the requested documents were in existence and it did not specify that Béarence was to create documents- and, if it had, such an order would be appealable); and the order had knowlingly and intentionally been violated (there was reasonable doubt in this regard).

Accordingly, no contempt declaration was made.

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Tax Topics - Income Tax Act - Section 231.2 - Subsection 231.2(1) no obligation to reformat previously-provided information 146
Tax Topics - Excise Tax Act - Section 289 - Subsection 289(1) no requirement to provide information in reformatted form 115

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

imprisonment if failure to pay fine for contempt, and provide bank statments, within 30 days

The respondent (“Chi”) failed to supply banking documents under a June 2016 Request for Information pursuant to s. 231.2(1) and subsequent October 2017 Compliance Order pursuant to s. 231.7. At issue were banking records and statements for three accounts registered at an HSBC branch in Hong Kong in the name of corporations owned or controlled directly or indirectly by the taxpayer, and a fourth TD Bank account. Mosley J, on a motion brought ex parte by the Minister was satisfied that there was a prima facie case of contempt of the Compliance Order, and in April 2018 ordered Chi to attend the Court’s general sittings in Ottawa (the “Show-Cause Order”). Chi, who was present at the show-cause hearing and testified as to why he should not be found in contempt of the order, provided the TD bank statements (only) at that time. In finding Chi to be in contempt, LeBlanc J stated (at paras. 40, 45):

… [T]he evidence … displays sporadic attempts by Mr. Chi to contact representatives at the HSBC in Hong Kong to obtain the bank statements at issue, most of them fruitless as Mr. Chi either failed to follow-up on information provided or failed to obtain the evidence that could support his contention that he is unable to comply with the Compliance Order.

…[T]he evidence before me points not to a clear and unequivocal effort to comply, but rather leads me to conclude, beyond a reasonable doubt, that Mr. Chi has demonstrated a “serious indifference or contemptuous disregard at the Court” ... .

After noting (at para. 35) that there were mitigating factors calling for a milder sentence than in other cases, LeBlanc J ordered Chi to pay a fine of $2,000 and legal costs of $3,500, and provide the HSBC bank statements (or documented evidence that they were unavailable) all within 30 days, failing which Chi would be subjected to 15 days’ imprisonment.