The applicant accounting firm sought judicial review of a Requirement to provide information (RFI) issued by the Minister of National Revenue under subsection 231.2(1) of the Income Tax Act.
The RFI was issued in the course of an audit of three of the firm's clients and requested information regarding the clients and "entities owned, operated, controlled or otherwise connected" to them.
The applicant argued the Minister was required to seek judicial authorization under subsections 231.2(2) and (3) because the RFI sought information about unnamed persons.
The Court dismissed the application, finding the Minister reasonably concluded the information was required to verify the compliance of the named taxpayers under audit, not to investigate the unnamed entities.
The Court also held the Minister reasonably addressed the RFI to the partnership and that the RFI was sufficiently clear.
