What is the test for disclosure of personal information to the Revenue Service of Canada?

Canada (Federal), Canada

The following excerpt is from 462657 Ontario Ltd. v. M.N.R. (T.D.), 1989 CanLII 5291 (FC), [1989] 3 FC 669:

Even if this were a seizure, I would still not find it unreasonable at least on the basis of the information before me. What is reasonable depends in part on whether a seizure runs counter to a reasonable expectation of privacy: Hunter v. Southam Inc. (1984), 1984 CanLII 33 (SCC), 11 D.L.R. (4th) 641, 14 C.C.C. (3d) 97, [1984] 2 S.C.R. 145 (S.C.C.). The administration of the Income Tax Act relies very heavily on self-reporting by taxpayers. It is the nature of income taxation that taxpayers must disclose all manner of financial information which in other circumstances might be considered highly personal and private. Where there is a reasonable suspicion that such disclosure has not been made then taxation authorities may have to seek the information which they honestly believe has not been provided. No taxpayer has a reasonable expectation of secrecy vis-à-vis revenue officials in respect of information, sought by them in good faith, pertaining to his taxable income. The compelling of disclosure of such information, therefore, conflicts with no reasonable expectation.

Other Questions


What is the current state of the law regarding the disclosure of personal information by the Canada Revenue Agency? (Canada (Federal), Canada)
What is the test for an employer to enforce an obligation to render personal service or to employ another in personal service? (MultiRegion, United States of America)
Is a waiver to supersede personal information superseding personal information enforceable? (MultiRegion, United States of America)
What is the relevant case law in relation to disclosure of allegations against the Correctional Service of Canada? (Canada (Federal), Canada)
What is the test for determining whether a person who has been living in Canada for more than a decade can be considered a resident of Canada? (Canada (Federal), Canada)
What is the test for disclosure of personal information in a civil case? (MultiRegion, United States of America)
What is the current state of the law regarding disclosure of personal information? (MultiRegion, United States of America)
What is the current state of the law on disclosure of personal information obtained from a motor vehicle records database? (MultiRegion, United States of America)
What is the current state of the law on disclosure of personal information obtained from a motor vehicle records database? (MultiRegion, United States of America)
What are some of the key decisions of the Court of Appeal of Canada on the determination of a person's residence where they have left Canada? (Canada (Federal), Canada)
X



Alexi white


"The most advanced legal research software ever built."

Trusted by top litigators from across North America.