Canada (National Revenue) v. Liang

Decided: 2026-09-09. Docket: T-2242-25. Citation: 2026 FC 1102 (CanLII). Taxation — Audit and enforcement — Compliance orders — Income Tax Act, subs. 231.7(1) — Demands under s. 231.1(1) for information and documents for audits — Whether a compliance order should issue with restrictions — Outstanding material and “basket clauses” assessed — Order framed by respondent and timing adjusted — Compliance order issued, no costs | Taxation — Income Tax Act — Compliance order conditions — Income Tax Act, ss. 231.1, 231.7 — Has the Minister clearly met the statutory preconditions for a compliance order? — Residency arguments raised but Federal Court lacks jurisdiction to determine residency — “Taxpayer” and “person” definitions applied based on filing and reporting — Conditions met except for speci