Questions? Call 416-367-4222

The Canada Revenue Agency (the Canadian income tax department, “CRA”) has broad powers to require the production of documents and information including the right to compel the production of “third party information” under section 231.2 of the Income Tax Act. The recent decision in eBay Canada Limited et al v MNR 2008 FCA 348 demonstrates that taxpayers are not afforded much protection under subsection 231.2(3) should the Minister of National Revenue decide to conduct an “audit project” targeted at a specific group of taxpayers, such as eBay PowerSellers.


"This article provides information of a general nature only. It is only current at the posting date. It is not updated and it may no longer be current. It does not provide legal advice nor can it or should it be relied upon. All tax situations are specific to their facts and will differ from the situations in the articles. If you have specific legal questions you should consult a lawyer."

Get your CRA tax issue solved

Address: Rotfleisch & Samulovitch P.C.
2822 Danforth Avenue Toronto, Ontario M4C 1M1

CRA’s right to compel the production of “third party information”
A growing business
Taxation for eBay & Resellers: Canadian Tax Lawyer’s Guide
CRA Tax Audit Of Loss Carryovers Exceeding $200,000
CRA Tax Audit of Loss Carryovers Exceeding $200,000
Losses On Investment in a small business corporation may be claimed as a business investment loss
PayPal CRA Court Order – When Shared Economy Becomes Underground Economy
Taxation of Ebay Sellers
An Allowable Business Invesment Loss
Loss On Investment
Taxation of Turo Car Rental Income– Toronto Tax Lawyer Comment