Section 231.7

Subsection 231.7(1) - Compliance order

Cases

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

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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

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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

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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

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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

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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

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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

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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

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See Also

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

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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

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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)

Cases

Canada (Minister of National Revenue) v. Les DĂ©veloppements BĂ©arence Inc., 2019 FC 22

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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

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