- Parties: The applicant was the Minister of National Revenue. The respondent was S. Robert Chad. 

- Subject Matter: The applicant filed a summary application under s. 231.7 of the Income Tax Act for a compliance order requiring the respondent to provide it with information under ss. 231.1 and 231.2 of the Act. The respondent was associated with certain non-resident corporations or trusts. The information sought by the applicant concerned these non-resident entities. The respondent claimed that he lacked the ability to produce documents and information relating to the entities. 

- Ruling: The court ruled in the respondent’s favour; dismissed the summary application for a compliance order concerning CF Trust, Ralphie Trust, Pedigree, Czech International, Oz Management, and BKR Trust; and ordered that the asset protection documents be filed with the court under seal within 30 days for evaluation of solicitor-client privilege. The court found, on a balance of probabilities, that the respondent made reasonable efforts to satisfy the requirement and that a compliance order would be futile since the respondent did not and could not possess the documents and information from these entities. The respondent was able to persuade the court about the distinction between control and access to the information as a limiting factor in the inability to provide the documents. 

- Date: The hearing was set on Sept. 12, 2023. The court released its decision on Mar. 22, 2024. 

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

- Amount: The court awarded the respondent costs.