The respondent Minister brought motions under sections 86 and 99 of the Tax Court of Canada Rules (General Procedure) seeking to examine the appellants' father as a non-party and to compel a brokerage firm to produce account records.
The Minister alleged the appellants received unreported shareholder benefits from offshore trading accounts.
The Court granted the motions, finding the father had relevant information not obtainable elsewhere and that the brokerage records were likely relevant to tracing the funds.
