Muller v. Canada (National Revenue)

Muller v. Canada (National Revenue)

The Federal Court of Appeal upheld the Federal Court's interpretation that ss.231.1(1) and (3) of the Income Tax Act authorize inspection and examination of electronic records seized from a taxpayer, and found no reviewable error in the lower court's dismissal of the motion to set aside the ex parte order and warrant.

Source-derived case information.

Citation
2016 FCA 260
Parties
Appellant: Patrick Muller; Respondent: The Minister of National Revenue
Court
Federal Court of Appeal
Jurisdiction
Canada
Judgment Date
24 October 2016
Procedural Posture
Appeal / Dismissal of Appeal From Federal Court Decision (motion to Set Aside Ex Parte Order and Warrant)
Outcome
Appeal dismissed
Legal Topics
Interpretation of Income Tax Act S.231.1, Inspection of Electronic Records, Ex Parte Orders and Warrants, Judicial Review of Statutory Interpretation
Source Language
en
Tax Law Administrative Law Privacy and Search and Seizure Electronic Evidence Interpretation of Income Tax Act S.231.1 Inspection of Electronic Records Ex Parte Orders and Warrants Judicial Review of Statutory Interpretation

Source-derived case record

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Parties

Patrick Muller

Appellant

The Minister of National Revenue

Respondent

Procedural Posture

Appeal / Dismissal of Appeal From Federal Court Decision (motion to Set Aside Ex Parte Order and Warrant)

  1. 1 Whether subsections 231.1(1) and (3) of the Income Tax Act authorize inspection and examination of electronic records seized from a taxpayer
  2. 2 Whether the Federal Court erred in refusing to set aside an ex parte order and warrant authorizing examination of computers

Ratio Decidendi

The Federal Court of Appeal upheld the Federal Court's interpretation that ss.231.1(1) and (3) of the Income Tax Act authorize inspection and examination of electronic records seized from a taxpayer, and found no reviewable error in the lower court's dismissal of the motion to set aside the ex parte order and warrant.

Court Disposition

Appeal dismissed

Orders

  • Appeal dismissed
  • No order as to costs