Section 241

See Also

Fio Corporation v. The Queen, 2014 TCC 58

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) implied undertaking of confidentiality during discovery 196
Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) inherent jurisdiction to void reassessments which breach undertaking 149
Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Act - Section 17.2 time of commencement of appeal 150

Subsection 241(1) - Provision of information

Cases

Summers v. Canada (National Revenue), 2014 DTC 5112 [at 7267], 2014 FC 880

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Other locations for this summary
Tax Topics - Other Legislation/Constitution - Federal - Access to Information Act - Section 24 - Subsection 24(1) taxpayer not entitled to request information about tax-shelter corporation

The Queen v. Diversified Holdings Ltd., 91 DTC 5029 (FCA)

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Tucar v. Tucar, 81 DTC 5166 (Ont. U.F.C.)

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See Also

Crestbrook Forest Industries Ltd. v. The Queen, 92 DTC 6187, [1992] 1 CTC 100 (FCA)

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In re MNR v. Huron Steel Fabricators (London) Ltd., 73 DTC 5347, [1973] CTC 422 (FCA)

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Administrative Policy

23 December 2013 Internal T.I. 2013-0498811I7 - Confidentiality of Non-resident Account Number

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88 C.R. - "Confidentiality of Taxpayer Information" - "Communication of Information with Foreign States"

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87 C.R. - Q41

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Articles

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

Subsection 241(2) - Evidence relating to taxpayer information

Cases

Diversified Holdings Ltd. v. The Queen, 89 DTC 5294, [1989] 2 CTC 10 (FCTD)

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Subsection 241(3) - Communication where proceedings have been commenced

Cases

Hanif's International Foods Ltd. v. The Queen, 2008 DTC 6630 (Alta. Prov. Ct.)

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The Queen v. Harris, 2001 DTC 5247 (FCA)

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Attorney - General of Canada and Bassermann (1994), 114 DLR (4th) 104 (FCA)

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Slattery (Trustee of) v. Slattery, 93 DTC 5443, [1993] 3 S.C.R. 430, [1993] 2 CTC 243

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Words and Phrases
relating to in respect of

Tyler v. MNR, 89 DTC 5044, [1989] 1 CTC 153 (FCTD), rev'd 91 DTC 5022 (FCA)

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Wiens v. The Queen, 88 DTC 6243 (FCTD)

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A.G. Canada v. Thibault, 87 DTC 5085, [1987] 1 CTC 156 (Que. C.A.)

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Paragraph 241(3)(b)

Cases

Canada (Attorney General) v. Fink, 2017 FCA 87

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Federal - Financial Administration Act - Section 23 - Subsection 23(2) relief provided to other taxpayers in somewhat similar circumstances was relevant to this case 204

Subsection 241(3.5)

Administrative Policy

Frequently asked questions - Canada emergency wage subsidy (CEWS) CRA Webpage December 2020

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(9) - Paragraph 125.7(9)(a) 150
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(1) - Qualifying Entity - Paragraph (c) - Subparagraph (c)(ii) 236
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(4) - Paragraph 125.7(4)(d) 725
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(4) - Paragraph 125.7(4)(a) 401
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(4) - Paragraph 125.7(4)(b) 367
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(1) - Eligible Employee 637
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(1) - Eligible Remuneration 474
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(2) - Element B 245
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(1) - Qualifying Revenue 962
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(1) - Eligible Entity - Paragraph (f) 79
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(1) - Eligible Entity - Paragraph (a) 236
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(1) - Qualifying Entity - Paragraph (d) - Subparagraph (d)(ii) 170
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(9) - Paragraph 125.7(9)(b) 379
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(g.5) 198
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(4.1) 194
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(1) - Top-Up Percentage 333
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(1) - Base Percentage 175
Tax Topics - General Concepts - Agency 78
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(1) - Baseline Remuneration 267

Subsection 241(4) - Where taxpayer information may be disclosed

Paragraph 241(4)(a)

Cases

In re Glover, 80 DTC 6262, [1980] CTC 531, aff'd 82 DTC 6035, [1982] CTC 29, [1981] 2 S.C.R. 561

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See Also

Ingenious Media Holdings plc & Anor, R (on the application of) v Commissioners for HMRC, [2016] UKSC 54

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Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Principle of Legality common law of confidentiality not overridden by general words 335

Administrative Policy

May 2015 Alberta CPA Roundtable, Q.1 (Plenary Session)

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Paragraph 241(4)(b)

Administrative Policy

August 1992 Memorandum (Tax Window, No. 23, p. 8, ¶2152)

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88 C.R. - "Confidentiality of Taxpayer Information" - "Section 241 of the Income Tax Act"

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Paragraph 241(4)(e)

Administrative Policy

19 August 1992 Memorandum 921931 (April 1993 Access Letter, p. 152, ¶C220-031)

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Paragraph 241(4)(k)

Administrative Policy

14 March 2013 Internal T.I. 2012-0451131I7 - Trustee's Rights & Obligations under the Act

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Subsection 241(9.5)

Administrative Policy

26 February 2015 CBA Roundtable, Q. 1

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 295 - Subsection 295(5.01) strict limits on provision of evidence to police 53

Subsection 241(10)

Taxpayer Information

Cases

783783 Alberta Ltd. (Vue Weekly) v. The Queen, 2010 DTC 5125 [at 7064], 2010 ABCA 226

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