Section 13
Subsection 13(1)
Paragraph 13(1)(a)
Cases
3412229 Canada Inc. v. Canada (Revenue Agency), 2020 FC 1156
The applicants, who were awarded damages in Ludmer regarding CRA’s conduct of its audit of their investments in an off-shore company and who had...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Federal - Access to Information Act - Section 16 - Subsection 16(1) - Paragraph 16(1)(b) | audit techniques re application of s. 94.1, and risk assessment tool used to manage the risks of an ongoing audit, were exempted | 217 |
| Tax Topics - Other Legislation/Constitution - Federal - Access to Information Act - Section 19 - Subsection 19(1) | names of Bermuda individuals with whom CRA had spoken were protected personal information | 187 |
| Tax Topics - Other Legislation/Constitution - Federal - Access to Information Act - Section 21 - Subsection 21(1) - Paragraph 21(1)(a) | government documents initially analyzing a problem and recommending a solution are exempted | 219 |
| Tax Topics - Other Legislation/Constitution - Federal - Access to Information Act - Section 24 - Subsection 24(1) | taxpayer information can only be disclosed in prescribed circumstances | 174 |
Section 16
Subsection 16(1)
Paragraph 16(1)(b)
Cases
3412229 Canada Inc. v. Canada (Revenue Agency), 2020 FC 1156
The applicants, who were awarded damages in Ludmer regarding CRA’s conduct of its audit of their investments in an off-shore company and who had...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Federal - Access to Information Act - Section 13 - Subsection 13(1) - Paragraph 13(1)(a) | all information communicated under Bermuda TIEA was protected confidential information | 308 |
| Tax Topics - Other Legislation/Constitution - Federal - Access to Information Act - Section 19 - Subsection 19(1) | names of Bermuda individuals with whom CRA had spoken were protected personal information | 187 |
| Tax Topics - Other Legislation/Constitution - Federal - Access to Information Act - Section 21 - Subsection 21(1) - Paragraph 21(1)(a) | government documents initially analyzing a problem and recommending a solution are exempted | 219 |
| Tax Topics - Other Legislation/Constitution - Federal - Access to Information Act - Section 24 - Subsection 24(1) | taxpayer information can only be disclosed in prescribed circumstances | 174 |
Section 18
Cases
Canadian Council of Christian Charities v. Canada (Minister of Finance), 99 DTC 5337, [1999] 3 CTC 123 (FCTD)
Evans J. indicated (at p. 5342) that although the words "injurious to the financial interest of the government of Canada" in s. 18(d) should not...
Section 19
Subsection 19(1)
Cases
3412229 Canada Inc. v. Canada (Revenue Agency), 2020 FC 1156
The applicants sought judicial review under s. 41 of the Access to Information Act (“ATIA”), of CRA’s decision to exempt various documents...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Federal - Access to Information Act - Section 13 - Subsection 13(1) - Paragraph 13(1)(a) | all information communicated under Bermuda TIEA was protected confidential information | 308 |
| Tax Topics - Other Legislation/Constitution - Federal - Access to Information Act - Section 16 - Subsection 16(1) - Paragraph 16(1)(b) | audit techniques re application of s. 94.1, and risk assessment tool used to manage the risks of an ongoing audit, were exempted | 217 |
| Tax Topics - Other Legislation/Constitution - Federal - Access to Information Act - Section 21 - Subsection 21(1) - Paragraph 21(1)(a) | government documents initially analyzing a problem and recommending a solution are exempted | 219 |
| Tax Topics - Other Legislation/Constitution - Federal - Access to Information Act - Section 24 - Subsection 24(1) | taxpayer information can only be disclosed in prescribed circumstances | 174 |
Section 21
Subsection 21(1)
Paragraph 21(1)(a)
Cases
3412229 Canada Inc. v. Canada (Revenue Agency), 2020 FC 1156
The applicants sought judicial review under s. 41 of the Access to Information Act (“ATIA”), of CRA’s decision to exempt various documents...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Federal - Access to Information Act - Section 13 - Subsection 13(1) - Paragraph 13(1)(a) | all information communicated under Bermuda TIEA was protected confidential information | 308 |
| Tax Topics - Other Legislation/Constitution - Federal - Access to Information Act - Section 16 - Subsection 16(1) - Paragraph 16(1)(b) | audit techniques re application of s. 94.1, and risk assessment tool used to manage the risks of an ongoing audit, were exempted | 217 |
| Tax Topics - Other Legislation/Constitution - Federal - Access to Information Act - Section 19 - Subsection 19(1) | names of Bermuda individuals with whom CRA had spoken were protected personal information | 187 |
| Tax Topics - Other Legislation/Constitution - Federal - Access to Information Act - Section 24 - Subsection 24(1) | taxpayer information can only be disclosed in prescribed circumstances | 174 |
See Also
John Doe v. Ontario (Finance), 2014 SCC 36, [2014] 2 S.C.R. 3
The appellant, a lawyer, filed a request for information with the Ministry of Finance, pursuant to the Ontario Freedom of Information and...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Redundancy/reading in words | "advice" in "advice or recommendations" can't only entail "recommendations" | 170 |
Section 21.1
Cases
Canadian Council of Christian Charities v. Minister of Finance, 2000 DTC 5337 (FCTD)
Before affirming a decision to withhold disclosure of certain documents, Evans J. stated (at p. 5342) with respect to the scope of the exemptions...
Section 24
Subsection 24(1)
Cases
3412229 Canada Inc. v. Canada (Revenue Agency), 2020 FC 1156
The applicants sought judicial review under s. 41 of the Access to Information Act (“ATIA”), of CRA’s decision to exempt various documents...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Federal - Access to Information Act - Section 13 - Subsection 13(1) - Paragraph 13(1)(a) | all information communicated under Bermuda TIEA was protected confidential information | 308 |
| Tax Topics - Other Legislation/Constitution - Federal - Access to Information Act - Section 16 - Subsection 16(1) - Paragraph 16(1)(b) | audit techniques re application of s. 94.1, and risk assessment tool used to manage the risks of an ongoing audit, were exempted | 217 |
| Tax Topics - Other Legislation/Constitution - Federal - Access to Information Act - Section 19 - Subsection 19(1) | names of Bermuda individuals with whom CRA had spoken were protected personal information | 187 |
| Tax Topics - Other Legislation/Constitution - Federal - Access to Information Act - Section 21 - Subsection 21(1) - Paragraph 21(1)(a) | government documents initially analyzing a problem and recommending a solution are exempted | 219 |
Summers v. Canada (National Revenue), 2014 DTC 5112 [at 7267], 2014 FC 880
The taxpayer participated in an alleged tax avoidance scheme involving the subscription of units in a corporation that generated dubious business...
| Other locations for this summary | |
|---|---|
| Tax Topics - Income Tax Act - Section 241 - Subsection 241(1) | taxpayer not entitled to request information about tax-shelter corporation |