Injunctive Relief Denied in Challenge to CRA-IRS Information Sharing

In Virginia Hillis and Gwendolyn Louise Deegan v. the Attorney General of Canada 2015 FC 1082, the plaintiffs argued that the Canada Revenue Agency’s (the “CRA”) disclosure of information related to accounts held by U.S. citizens at Canadian banks to the Internal Revenue Service was contrary to section 241 of the Income Tax Act, which restricts the ability of the CRA to share taxpayer information. The plaintiffs sought an injunction to stop the planned disclosure, which will take place on September 30, 2015. Justice Martineau dismissed a motion for injunctive relief in a decision rendered on September 16, 2015, though the constitutionality of the information sharing  remains to be considered at trial.