- Parties: The applicant was the Minister of National Revenue. The respondent was Jurgen Schreiber. 

- Subject Matter: In 2022, the Canada Revenue Agency commenced an audit of the respondent for the Jan. 1, 2016 to Dec. 31, 2019 taxation years. The Minister of National Revenue requested a compliance order under s. 231.7 of the Income Tax Act, 1985 to require the respondent to provide it with documents and information that a July 5, 2022 demand sought from him. 

- Ruling: The court partly granted the application and ordered the respondent to provide the applicant with certain documents and information for the audit period under the demand, as well as a personal affidavit providing the particulars or results of his search efforts for material relating to documentation from 2016. The court ordered the respondent to conduct a detailed search for the outstanding materials from 2016. The court found him unable to show that these documents did not exist, that the information was unavailable, or that he made reasonable efforts to obtain this information. The court also held that residency did not necessarily preclude the Minister from seeking information under ss. 231.1 and 231.7, given the provisions’ text, context, and purpose. 

- Date: The hearing was set on Sept. 19, 2023. The court released its decision on May 13, 2024. 

- Venue: This was a federal case before the Federal Court. 

- Amount: The court awarded no costs as the parties agreed to settle the matter of costs out of court.