The Federal Tax Court of Canada has ruled that the tax authorities acted properly in ordering accounting firm Zeifmans to disclose information and documents on unnamed ’entities owned, operated, controlled or otherwise connected to’ a family which it advised. Zeifmans challenged the Canada Revenue Agency’s (CRA’s) authority to issue the demand without judicial authorisation, but the court ruled that, under s.231.2 of the Income Tax Act, the CRA does not need judicial authorisation to issue a demand against unnamed persons that are not themselves under tax audit (Zeifmans LLP v MNR, 2021 FC 363). The decision has been appealed to the Federal Court of Appeal.
News Source：【Thorsteinssons 2021/07/14】