Documents requested pursuant to a requirement for information under s. 288(1) of the Excise Tax Act (Canada) need not be proportional to matter at issue
In Canada (National Revenue) v. 2276230 Ontario, 2021 FC 242, the Federal Court granted a compliance order to the CRA citing the Federal Court of Appeal’s decision in Canada (National Revenue) v. Cameco Corporation, 2019 FCA 67, 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”.