The applicants sought judicial review to quash three requests for information sent by the Canada Revenue Agency (CRA) to the Swiss Federal Tax Administration.
The CRA suspected the applicants had unreported foreign assets and issued the requests under the Canada-Switzerland Income Tax Convention.
The applicants argued the CRA acted on illegally obtained confidential information, violated solicitor-client privilege, and failed to exhaust domestic avenues.
The Federal Court applied the reasonableness standard and found the CRA had the authority to issue the requests and complied with statutory requirements.
The Court dismissed the applications with costs.
