Section 232

Subsection 232(1) - Definitions

Judge

Cases

Bank of Nova Scotia v. Deputy Attorney General of Canada, 92 DTC 6313 (Ont. Ct. (G.D.))

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Solicitor-Client Privilege

Cases

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 231.7 - Subsection 231.7(1) low threshold of relevance was met 274

Iggillis Holdings Inc. v. Canada (National Revenue), 2018 FCA 51

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Iggillis Holdings Inc. v. Canada (National Revenue), 2016 FC 1352, rev'd 2018 FCA 51

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Canada (National Revenue) v. Thompson, 2016 SCC 21, [2016] 1 S.C.R. 381

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Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Hansard, explanatory notes, etc. Hansard indicated an intent for an amendment to trench on privilege 103
Tax Topics - Statutory Interpretation - Redundancy/reading in words presumption against tautology 114

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 231.2 - Subsection 231.2(1) s. 231.2 does not apply to lawyers 123

Inwest Investments Ltd. v. The Queen, 2015 BCSC 1375

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) reasonable filing position position cannot be a “misrepresentation” 508
Tax Topics - Income Tax Regulations - Regulation 400 - Subsection 400(2) no fixed place of “business” if no source of business income 165
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business Marconi test of "business" applied outside source-of-income context 136
Tax Topics - Statutory Interpretation - French and English Version "misrepresentation" informed by narrower French version 103

Canada v. Superior Plus Corp., 2015 DTC 5118 [at 6319], 2015 FCA 241, aff'g 2015 TCC 132

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) Minister compelled to disclose GAAR memoranda and minutes, and Finance correspondence, as relevant to alleged policy 423

Canada (National Revenue) v. Revcon Oilfield Constructors Incorporated, 2015 FC 524, aff'd 2017 FCA 22

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Canada (Attorney General) v. Federation of Law Societies of Canada, 2015 SCC 7, [2015] 1 S.C.R. 401

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 7 state cannot impose duties that undermine lawyer's duty of commitment to client's cause 248
Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 8 Charter protection against statutory erosion of privilege extends beyond a criminal context and includes client identity 355

Equipment Ltd. v. The Queen, 2014 DTC 5102 [at 7176], 2014 SKQB 172

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Dr. Mike Orth Inc. v. Canada, 2014 DTC 6685, 2014 FCA 34

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Thompson v. Canada (National Revenue), 2013 DTC 5146 [at 6296], 2013 FCA 197, rev'd 2016 SCC 21

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Canada (National Revenue) v. Thornton, 2013 DTC 5008 [5541], 2012 FC 1313

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Canada (National Revenue) v. Clark, 2012 DTC 5143 [at 7324], 2012 FC 950

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R. v. Defehr, 2012 DTC 5005 [at 6514], 2011 BCSC 1548

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Taxpro Professionnal Corporation v. Canada (National Revenue), 2012 DTC 5002 [at 6506], 2011 FCA 306

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Barrick Gold Corporation v. Goldcorp Inc., 2011 ONSC 1325

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Camp Development Corporation v. South Coast Greater Vancouver Transportation Authority, 2011 BCSC 88

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Bank of Montreal v. Tortora, 2010 BCSC 1430

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Canada (Minister of National Revenue) v. Vlug, 2006 DTC 6285, 2006 FC 86

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Canada (Minister of National Revenue) v. Reddy, 2006 DTC 6178, 2006 FC 277

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Canada (Minister of National Revenue) v. Welton Parent Inc., 2006 DTC 6093, 2006 FC 67

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Canada (Minister of National Revenue) v. Singh Lyn Ragonetti Bindal LLP, 2005 DTC 5703, 2005 FC 1538

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

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Pitney Bowes of Canada Ltd. v. The Queen, 2003 DTC 5179 (FCTD)

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Fraser Milner Casgrain LLP v. MNR, 2003 DTC 5048 (BCSC)

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College of Physicians of British Columbia v. British Columbia (Information and Privacy Commissioner), [2002] BCJ No. 2779 (CA)

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Belgravia Investments Ltd. v. The Queen, 2002 DTC 7133 (FCTD)

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AFS & Co. Limited Partnership No. 5 v. The Queen, 2001 DTC 5330 (FCTD)

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Nathawad v. The MNR, 2001 DTC 5069 (BCSC)

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General Accident Assurance Co. v. Chrusz, [1999] O.J. No. 3291 (CA)

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Archean Energy Ltd. v. MNR, 98 DTC 6456 (Alta. Q.B.)

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Bentley v. Stone (1998), 42 OR (3d) 149 (Gen Div)

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Verney v. Great-West Life Assurance Co. (1998), 38 OR (3d) 475 (Gen Div), aff'd (1998), 40 OR (3d) 249 (Div Ct).

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

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Toronto-Dominion Bank v. Leigh Instruments (1997), 32 O.R. (3d) 575 (Gen. Div.)

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Interprovincial Pipe Lines Inc. v. MNR, 95 DTC 5642 (FCTD)

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Eastwood & Co. v. MNR, 94 DTC 6411 (BCSC)

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Cineplex Odeon Corp. v. A.G. of Canada, 94 DTC 6407 (Ont. Ct. (G.D.))

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

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 231.2 109

Gregory v. MNR, 92 DTC 6518 (FCTD)

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Bank of Nova Scotia v. Deputy Attorney General of Canada, 92 DTC 6313 (Ont. Ct. (G.D.))

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Organic Research Inc. v. M.N.R ., [1991] 1 CTC 417 (Alta. Q.B.)

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Southern Railway of British Columbia Ltd. v. Deputy Minister of National Revenue, Taxation, [1991] 1 CTC 432 (BCSC)

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Dixon v. Deputy Attorney General of Canada, 91 DTC 5584 (Ont HCJ.)

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Southern Railway of British Columbia Ltd. v. Deputy Minister of National Revenue, Taxation, 91 DTC 5081 (BCSC)

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Zein v. The Queen, 91 DTC 5052 (BCSC)

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Roseland Farms Ltd. v. The Queen, 90 DTC 6512 (FCTD)

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Baron v. The Queen, 91 DTC 5055 (FCA)

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Heath v. The Queen, 90 DTC 6069 (BCSC)

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MNR v. Canadian Bio-Mass Research Inc., 89 DTC 5123 (FCTD)

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Visser v. MNR, 89 DTC 5172 (P.E.I.S.C.)

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Mutual Life Assurance Co. of Canada v. Dep. A.G. of Canada, 88 DTC 6511 (S.C.O.)

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Re Cox, 88 DTC 6494, [1988] 2 CTC 365 (BCSC)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Stare Decisis 27

In re Playfair Developments Ltd., 85 DTC 5155, [1985] 1 CTC 302 (S.C.O.)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 232 - Subsection 232(5) 39

Dep. Min. of Rev. of Quebec v. Fava., [1984] CTC 584 (Que. C.A.)

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Mutual Life Insurance Co. of Canada v. Dep. A.G. of Canada, 84 DTC 6177, [1984] CTC 155 (Ont HC)

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Crown Zellerback Canada Ltd. v. Dep. A.-G. (Canada), 82 DTC 6116, [1982] CTC 121 (BCSC)

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In re Cotrono, 82 DTC 6068, [1982] CTC 67 (FCTD)

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In re Romeo's Place Victoria Ltd., 81 DTC 5295, [1981] CTC 380 (FCTD)

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In re Hoyle Industries Ltd., 80 DTC 6363, [1980] CTC 501 (FCTD)

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Edmonds v. Dept. A.G. (Canada), 80 DTC 6201, [1980] CTC 192 (QSC)

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Herman v. Dep. A.G. of Canada, 79 DTC 5372 (Ont CA)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 232 - Subsection 232(5) 54

Medicine Hat Greenhouse Ltd. and German v. R., 79 DTC 5091, [1980] CTC 114 (Alta. C.A.)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Abuse of Process delay in initiating a prosecution 63
Tax Topics - Income Tax Act - Section 244 - Subsection 244(4) 63

Susan Hosiery Ltd. v. The Queen, [1969] 2 Ex CR 27, 69 DTC 5278

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Rolka v. MNR, 62 DTC 1394, [1962] CTC 637 (Ex Ct)

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See Also

Hart v Commissioner of Taxation (No 3), [2017] FCA 571 (Federal Court of Australia)

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Canadian Imperial Bank of Commerce v. The Queen, 2015 DTC 1235 [at 1551], 2015 TCC 280

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Superior Plus Corp. v. The Queen, 2015 DTC 1124 [at 765], 2015 TCC 132, aff'd 2015 FCA 241

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) Minister compelled to disclose GAAR Committee and ATP memoranda and minutes, and correspondence with Finance, as they were relevant to the alleged policy abuse 457

Zeldap Corporation v. The Queen, 2015 DTC 1108 [at 636], 2015 TCC 78

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Cameco Corporation v. The Queen, 2014 TCC 45

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Evidence proportionality principle 182
Tax Topics - Income Tax Act - Section 169 - Subsection 169(1) appeals from superceded reassessments were nullities 54

Imperial Tobacco Canada Limited v. The Queen, 2013 TCC 144

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R. (Prudential plc & Anor) v. Special Commissioner of Income Tax & Anor, [2013] 2 All ER 309, [2013] UKSC 1

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506913 N.B. Ltd v. The Queen, 2012 TCC 210

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SoftSim Technologies Inc. v. The Queen, 2012 DTC 1187 [at 3473], 2012 TCC 181

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R (Ford) v. Financial Services Authority, [2012] 1 All ER 1238, [2011] EWHC 2583 (QBD)

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Richard A. Kanan Corporation v. The Queen, 2011 DTC 1168 [at 928], 2011 TCC 211 (Informal Procedure)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Onus 287

M.N.R. v. Newport Pacific Financial Group SA, 2010 DTC 5160 [at 7276], 2010 ABQB 568

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Copthorne Holdings Ltd. v. The Queen, 2005 DTC 1133, 2005 TCC 491

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Tower v. MNR, 2002 DTC 7315 (FCTD)

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Sumitomo Corp. v. Credit Lyonnais Rouse Ltd., [2002] 4 All ER 68 (CA)

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Bowne v. Person (2000), 185 DLR (4th) 335 (Man. CA)

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Verney v. Great-West Life Insurance Co. (1998), 40 OR (3d) 249 (DC)

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Balabel v. Air India, [1988] 2 WLR 1036 (C.A.)

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Rogers v. Bank of Montreal, [1985] 4 WWR 508 (BCCA)

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Descôteaux et al. v. Mierzwinski, [1982] 1 S.C.R. 860, 141 DLR (3d) 590.

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O'Reilly v. Commissioners of the State Bank of Victoria, 82 A.TC 4671 (HC)

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Administrative Policy

87 C.R. - Q.40

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84 C.R. - Q.90

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84 C.R. - Q.91

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Articles

Mark Tonkovich, "A Primer on Solicitor-client Privilege and Third-party Disclosure", Tax Litigation, Volume XIX, No. 1, 2013, p. 1141.

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Maria Italia, "Taxpayer Privilege in Australia, New Zealand, the United Kingdom, and the United States", Journal of International Taxation, August 2013, p. 47

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Robert Kopstein, Rebecca Levi, "When Should the Courts Allow Reassessments Beyond the Limitation Period", Canadian Tax Journal, (2010) Vol. 58, No. 3, 475-527

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Andrew W. Kingissepp, Sanjana Bikatta, "Solicitor-Client and Litigation Privilege-Current Canadian Issues", Journal of International Taxation, Vol. 19, No. 9, September 2008, p. 42.

Matthew Williams, "Three Rivers District Council (U.K.): Restricting the Scope of Legal Advice Privilege", Tax Litigation, Vol. XII, No. 1, 2004, p. 735.

Kent Roach, Edward Iacobucci, "Multidisciplinary Practices and Partnerships: Prospects, Problems and Policy Options", Canadian Bar Review, Vol. 79, No. 1, February 2000, p. 1.

Gloria Geddes, "The Fragile Privilege: Establish and Safeguarding Solicitor-Client Privilege", 1999 Canadian Tax Journal, Vol., 47, No. 4, p. 799: Includes discussion of the risks of the loss of the privilege in a multi disciplinary partnership.

G.D. Watson, F. Lau, "Solicitor-Client Privilege and Litigation Privilege in a Civil Litigation", Canadian Bar Review, Vol. 77, September - December 1998, p. 315.

Joel A. Nitikman, "Accountant's Privilege - Getting Closer to the Holy Grail?", Tax Litigation , Vol. VI, No. 3, 1998, p. 382.

J. Douglas Wilson, "Privilege in Experts' Working Papers", Canadian Bar Review , Vol. 76, September-December 1997, p. 346.

Laidlaw, "Solicitor-Client Privilege: To Disclose or not to Disclose Remains the Question, Even after Death", Estates and Trusts Journal , Vol. 15, No. 1, September 1995, p. 56.

McMechan, "Privileged Information", CA Magazine , March 1995, p. 46.

Watson, "Next Case, Please: Case-by-Case Privilege Offers Some Hope for Non-Lawyer Advisers", Canadian Current Tax , November 1993, p. P23.

Nathanson, "The Fairness Package, the Long Reach of Section 160, and Solicitor-Client Privilege", 1991 Conference Report , c. 49.

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

MacKnight, "Privileges of the Taxpayer", Practice Notes, Canadian Current Tax , February 1991, p. P27.

Subsection 232(3) - Seizure of certain documents where privilege claimed

Cases

Lavallee, Rackel & Heintz v. Canada (Attorney General); White, Ottenheimer & Baker v. Canada (Attorney General); R. v. Fink, 2002 DTC 7267, 2002 SCC 61, [2002] 3 S.C.R. 209

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 8 unconstitutional lack of privilege safeguards 200

Subsection 232(3.1) - Examination of certain documents where privilege claimed

Cases

R. v. Cappell, 92 DTC 6591 (Ont CA)

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Words and Phrases
about to
Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Ordinary Meaning 38

Subsection 232(4) - Application to judge

Paragraph 232(4)(a)

Cases

Gray v. Attorney General of Canada, 93 DTC 5518 (Ont. Ct. (G.D.))

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Solvent Petroleum Extraction Inc. v. MNR, 90 DTC 6261 (FCTD)

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Vespoli v. The Queen, 82 DTC 6314, [1982] CTC 365 (FCTD), aff'd (FCA)

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Herman et al. v. Deputy Attorney General (Canada), 78 DTC 6456, [1978] CTC 728, [1979] 1 S.C.R. 729

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Subsection 232(5) - Disposition of application

Cases

Taxpro Professional Corporation v. Canada (National Revenue), 2011 DTC 5036 [at 5635], 2011 FC 224

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594872 Ontario Inc., Salamon and Salbro Investments Inc. v. The Queen, 92 DTC 6234 (FCTD)

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In re Playfair Developments Ltd., 85 DTC 5155, [1985] 1 CTC 302 (S.C.O.)

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Vespoli v. The Queen, 83 DTC 5001, [1982] CTC 418 (FCTD), rev'd 84 DTC 6489, [1984] CTC 519 (FCA)

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In re Cotroneo, 82 DTC 6115, [1982] CTC 131 (FCTD)

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In re Romeo's Place Victoria Ltd., 81 DTC 5295, [1981] CTC 380 (FCTD)

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Herman v. Dep. A.G. of Canada, 79 DTC 5372 (Ont CA)

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Subsection 232(10) - Directions

Cases

Sheridan Warehousing Ltd. v. MNR, 80 D.CTC 6389 (SCO)

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