Canada (National Revenue) v. Liang

canada, canadian, case law, court opinion, canlii, fct, 2026fc1102, 2026 fc 1102 (canlii), 2026, fc, 1102, (canlii), t-2242-25, 2026, 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 specific unsupported requests, compliance order partly granted, statutory interpretation, income tax act, information, gathering powers, income tax act, ss. 231.1, 231.6, 231.7, whether demands for foreign bank accounts and offshore property must proceed under s. 231.6 rather than s. 231.1, “foreign, based information” and accessibility from canada analysed, overlap between provisions recognised, use of s. 231.1 upheld where information accessible, demands largely confirmed, procedure, federal court, scope and conditions of compliance, income tax act, ss. 231.5, 231.7(3), whether respondents made “reasonable efforts” and can be compelled to conduct further searches, possession, power or control and futility principles applied, additional steps ordered for searches and inquiries, with particulars in personal affidavits, obligations severed by respondent and timeline extended, compliance order issued with conditions, evidence, affidavits, admissibility, federal courts rules, rule 68, whether untranslated chinese exhibits may be relied on for the truth of their contents, distinction between audit record and truth of content applied, improper opinions on foreign law and domestic law struck, limited hearsay treatment for audit correspondence, specified paragraphs and exhibits struck, remaining given no weight where required, evidence partly struck