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”.

Prepared by: Leonard Gilbert , Chris Marta

Leonard graduated from the University of Toronto, Faculty of Law (J.D. 2015) and is currently an associate practicing in the firm’s Toronto office. He previously performed extensively as a concert pianist and attended the Jacobs School of Music at Indiana… more »

Chris Marta is an associate practising in the firm’s Vancouver office. Chris Marta’s practice focuses on domestic and international tax planning for individuals, trusts and corporations. He also represents taxpayers in their disputes with the Canada Revenue Agency. Prior to… more »