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.
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