Canada (National Revenue) v. Zeifmans LLP

canada, canadian, case law, court opinion, canlii, fca, 2026fca147, 2026 fca 147 (canlii), 2026, fca, 147, (canlii), a-260-23, 2026, procedure, compliance orders, income tax act, s. 231.7, requirements to provide information and documents, whether statutory preconditions met to compel compliance, de novo compliance proceeding and appellate intervention for legal error, order sought to compel production under s. 231.2, appeal allowed, compliance order granted, taxation, audit and enforcement powers, income tax act, ss. 231.2, 231.7, unnamed persons, whether prior judicial authorization under s. 231.2(3) was required, purpose test from canada (customs and revenue agency) v. artistic ideas inc. applied, requirement issued to further audits of named persons, judicial authorization not required, compliance ordered, statutory interpretation, vagueness, income tax act, s. 231.2 requirement, description of “entities owned, operated, controlled or otherwise connected”, whether requirement worded with sufficient precision to enable meaningful compliance, requirement read in context with information sheet, terms capable of interpretation not void for vagueness, requirement valid, compliance ordered, statutory interpretation, partnerships, income tax act, ss. 231.2(1), 244(20), requirement issued to partnership, whether partnership is a “person” for purposes of issuing a requirement, deeming provision treating notice as provided to each partner, service at place of business sufficient, requirement not invalid as addressed to partnership, compliance ordered, procedure, abuse of process, re, litigation, compliance proceedings after judicial review, whether challenging validity of requirement again was an abuse of process, differences between reasonableness review and de novo compliance proceeding assessed, “materially different” record and new evidence considered, re, litigation held abusive in circumstances, appeal allowed, compliance ordered