Minister of National Revenue v. Amdocs Canadian Managed Services Inc., 2015 FC 1234
| Jurisdiction | Federal Jurisdiction (Canada) |
| Judge | Russell, J. |
| Court | Federal Court (Canada) |
| Subject Matter | PRACTICE,INCOME TAX,CRIMINAL LAW,ADMINISTRATIVE LAW |
| Citation | 2015 FC 1234 |
| Date | 30 October 2015 |
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6 practice notes
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Canada (National Revenue) v. Dominelli, 2022 FC 187
...(National Revenue) v Lin, 2019 FC 646 at para 26, citing Canada (Minister of National Revenue) v Amdocs Canadian Managed Services Inc., 2015 FC 1234 at paras 75 and76). (3) What was done pursuant to the agreement? [37] Dominelli signed the undertaking on December 31, 2020, so his compliance......
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Miller v. Canada (National Revenue), 2022 FCA 183
...the possession, control or power of a taxpayer (see, for example, Canada (National Revenue) v. Amdocs Canadian Managed Services Inc., 2015 FC 1234 at paras. 33-34, 75-76, 2015 D.T.C. 5117; and Canada (National Revenue) v. Ghermezian, 2022 FC 236 at paras. 73-78, 2022 D.T.C. 5029). [72] In t......
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Can An Auditor Compel A Taxpayer To Create Documents?
...the Minister of National Revenue v. Amdocs Canadian Managed Services Inc. 2015 FC 1234, it was contemplated whether or not the Minister of National Revenue (Minister) could issue a compliance order to a taxpayer, compelling the taxpayer to create and provide information pursuant to section ......
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Blurring The Lines Between Inspection And Requirement Powers: Recent Legislative Amendments To Section 231.1
...Finance, "Explanatory Notes of the Legislative Proposals Relating to the Income Tax Act and Other Legislation", (February 2022) at 83. 13. 2015 FC 1234 at para. The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about......
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4 cases
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Canada (National Revenue) v. Dominelli, 2022 FC 187
...(National Revenue) v Lin, 2019 FC 646 at para 26, citing Canada (Minister of National Revenue) v Amdocs Canadian Managed Services Inc., 2015 FC 1234 at paras 75 and76). (3) What was done pursuant to the agreement? [37] Dominelli signed the undertaking on December 31, 2020, so his compliance......
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Miller v. Canada (National Revenue), 2022 FCA 183
...the possession, control or power of a taxpayer (see, for example, Canada (National Revenue) v. Amdocs Canadian Managed Services Inc., 2015 FC 1234 at paras. 33-34, 75-76, 2015 D.T.C. 5117; and Canada (National Revenue) v. Ghermezian, 2022 FC 236 at paras. 73-78, 2022 D.T.C. 5029). [72] In t......
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Blue Bridge Trust Company Inc. v. Canada (National Revenue), 2020 FC 893
...one’s possession or to create information or records that do not exist (Canada (National Revenue) v Amdocs Canadian Managed Services Inc., 2015 FC 1234 at para 75). [119] First, the issue of whether an amount has been disbursed as capital or income is a question of fact, not a matter of opi......
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Canada (National Revenue) v. Lin, 2019 FC 646
...for purposes of an audit is broad. As the Court stated in Canada (Minister of National Revenue) v Amdocs Canadian Managed Services Inc., 2015 FC 1234 [Amdocs]: [67] In effect, ACMS is asking the Court to decide that the Minister already has what is required to complete the TPA. However, as ......
2 firm's commentaries
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Can An Auditor Compel A Taxpayer To Create Documents?
...the Minister of National Revenue v. Amdocs Canadian Managed Services Inc. 2015 FC 1234, it was contemplated whether or not the Minister of National Revenue (Minister) could issue a compliance order to a taxpayer, compelling the taxpayer to create and provide information pursuant to section ......
-
Blurring The Lines Between Inspection And Requirement Powers: Recent Legislative Amendments To Section 231.1
...Finance, "Explanatory Notes of the Legislative Proposals Relating to the Income Tax Act and Other Legislation", (February 2022) at 83. 13. 2015 FC 1234 at para. The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about......