In Ghermezian v. Minister of National Revenue (Fed CA, 2023) the Federal Court of Appeal considered an appeal from Federal Court ITA s.231.7 'compliance orders' made in relation to Ministerial 'demands' under ITA s.231.1 ["Information gathering"] and s.231.2 ["Requirement to provide documents or information"]. At paras 14-42 the court considers an issue concerning the procedure accompanying ITA s.231.1:
[9] The appellants appeal the February 2022 judgment of the Federal Court (A-65-22) as well as the six subsequent compliance orders issued in July 2022 (A-151-22). While they raised other grounds in their notices of appeal, the appellants submit in their amended memorandum of fact and law that the Federal Court erred in holding that subsection 231.1(1) of the ITA empowered the Minister to compel the production of documents without physically attending the appellants’ business premises. ...
The author has waived all copyright and related or neighboring rights to this Isthatlegal.ca webpage.
