Federal appeal | Civil Practice and Procedure | Practice on appeal | Parties
Taxpayer appealed decision issuing compliance order under s. 231.7 of Income Tax Act requiring taxpayer to produce draft due diligence report to Canada Revenue Agency. Accountants’ professional association brought motion to intervene in appeal. Motion granted. Criteria for intervention were met. Accountants had useful and helpful role to play, concerning understanding of authentic meaning of s. 231.7 of Act. Practical experience of accountants would likely assist court in interpreting and applying s. 231.7 of Act. Accountants were likely to have useful perspective on issue of legislative purpose. It was appropriate that accountants be given leave to intervene on issues of legislative interpretation.
Atlas Tube Canada ULC v. Canada (Minister of National Revenue) (2019), 2019 CarswellNat 1691, 2019 FCA 120, David Stratas J.A. (F.C.A.).
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