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Canada Case Law

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Tax law 2025 FC 969

Canada (National Revenue) v. Shopify Inc.

The Federal Court dismissed the Minister’s application for an unnamed persons requirement, finding the proposed target group was not ascertainable.

  • Unnamed persons requirement
  • Ascertainable group
  • Income tax act s.231.2
  • Judicial authorization
  • Data production and matching
  • Privacy and cybersecurity
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National security law 2022 FC 645

Canadian Security Intelligence Service Act (CA) (Re)

The Federal Court authorized CSIS to retain two Canadian datasets for two years, subject to conditions on updates, access, deletions, and contextual reporting.

  • Dataset retention
  • Judicial authorization
  • Exigent circumstances
  • Data exploitation and querying
  • Intelligence oversight
  • Nsira review
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Constitutional law 2024 SCC 6

R. v. Bykovets

A majority of the Supreme Court held that an IP address can attract a reasonable expectation of privacy, so a state request for it is a search under s. 8.

  • Section 8 charter
  • Reasonable expectation of privacy
  • Ip address
  • Search and seizure
  • Third‑party disclosure
  • Production order
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Criminal law 2023 ONCA 614

R. v. Khamo

The Court concluded that where the Crown in related prosecutions concedes that the redacted ITO and judicial summaries are inadequate to permit meaningful challenge and cannot disclose more without compromising confidential informants, fairness requires a stay under s.24(1); materials from related proceedings may be admitted on appeal in the interest of justice, and therefore the convictions based on the challenged authorizations must be quashed and the prosecution stayed.

  • Communications interception
  • Judicial authorization
  • Garofoli motion
  • Judicial summaries
  • Redaction of ito
  • Confidential informants
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Tax law 2023 FC 1000

Canada (National Revenue) v. Zeifmans LLP

The Federal Court dismissed the Minister’s s. 231.7 compliance application against Zeifmans LLP, finding prior judicial authorization was required and not obtained.

  • Section 231.2
  • Section 231.7
  • Compliance order
  • Judicial authorization
  • Collateral attack
  • Abuse of process
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Tax law 2023 FC 980

Canada (National Revenue) v. Bambora Inc.

The Federal Court authorized the Minister to require Bambora Inc. to disclose information about identifiable merchants for tax verification purposes.

  • Information‑gathering orders
  • Audit and verification
  • Underground economy
  • Ascertainability of unnamed persons
  • Judicial authorization
  • Tax-law
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Criminal law 2022 BCSC 2333

R. v. Zacharias

In a voir dire, the court upheld two vehicle tracking warrants but set aside a telephone tracking warrant, finding the higher standard was not met.

  • Vehicle tracking warrant
  • Telephone tracking warrant
  • Tracking device surveillance
  • Reasonable suspicion standard
  • Section 8 charter
  • Section 9 charter
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Tax law 2021 FC 1438

Canada (National Revenue) v. Hydro-Québec

The Federal Court held that the Minister’s 2019 requirement for information against Hydro‑Québec was barred by res judicata and dismissed the application with costs.

  • Requirement for information (rfi) under s.231.2 income tax act
  • Res judicata (art. 2848 ccq)
  • Ascertainable group
  • Judicial authorization
  • Abuse of process
  • Res-judicata
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Taxation 2021 FC 830

Canada (National Revenue) v. Royal Bank of Canada

Federal Court authorized the Minister to require RBC to disclose account holder names and addresses, subject to removing one stated purpose from the requirement letter.

  • Information disclosure orders
  • Income tax act s.231.2
  • Third-party records
  • Judicial authorization
  • Income-tax-act
  • Judicial-authorization
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Tax law 2021 FC 363

Zeifmans LLP v. Canada (National Revenue)

The Federal Court dismissed Zeifmans LLP’s judicial review of a CRA requirement for information, finding no need for judicial authorization and no reviewable error.

  • Requirement to provide information
  • Income tax act s.231.2
  • Third party information requests
  • Judicial authorization
  • Standard of review (reasonableness)
  • Tax-law
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Canada decisions are organised by court, judge, legal area and indexed issue so a practitioner can move from a proposition to a citable authority with the surrounding context intact.