Background: The Canada Revenue Agency (CRA) audited the Ghermezian family under its Related Party Initiative since at least 2014. The appellants, members of the Ghermezian family and a related corporation, were involved in the case.

CRA's Demands: In the audit, the Minister of National Revenue issued various requests and requirements for documents/information under sections 231.1 and 231.2 of the Income Tax Act (ITA), which the appellants largely failed to fulfill by the deadlines.

Federal Court's Compliance Applications: Following the appellants' failure to provide required materials, the Minister filed six applications for compliance orders under section 231.7 of the ITA. The Federal Court granted these applications in February 2022.

Appellants' Appeal: The appellants appealed the judgment, challenging the Federal Court's interpretations of subsection 231.1(1) of the ITA. They argued that the Minister's demands were invalid and did not provide reasonable time for compliance.

Minister's Cross-Appeal: The Minister cross-appealed, contending that section 231.1 of the ITA did not authorize the compulsion of information other than contained in a document.

Federal Court of Appeal's Decision:

• Dismissed the appellants' appeals.
• Allowed the Minister's cross-appeals, finding the Federal Court erred in limiting the Minister's authority under subsection 231.1(1) to compel only documented information.

Outcome: The Federal Court of Appeal upheld the Federal Court's decision to grant the Minister's compliance applications, with modifications in line with the Minister's broader authority under subsection 231.1(1) of the ITA.