Canada (National Revenue) v. Shopify Inc.
The Federal Court held the Convention on Mutual Administrative Assistance in Tax Matters was not incorporated into ITA s. 231.2(3), and dismissed the Minister’s UPR application.
- Unnamed persons requirement (upr)
- Income tax act s.231.2
- Incorporation of treaties into domestic law
- Convention on mutual administrative assistance in tax matters
- Judicial discretion and feasibility of production orders
- Ascertainability of target groups