Redeemer Foundation v Canada (National Revenue), 2008 SCC 46, makes it clear that the CRA has broad powers to demand information relating to unnamed third parties, sometimes even without the need for prior judicial authorization (as per subsection 231.2(2)). Two recent cases from the Federal Court of Appeal make it clear that Minister’s powers under the Income Tax Act are not unlimited. See Canada (National Revenue) v Lordco Parts Ltd, 2013 FCA 49, and Canada (National Revenue) v RBC Life Insurance Company, 2013 FCA 50.
