CRA is now using s. 231.1 as its primary demand power, and is relegating s. 231.2 to special situations, e.g., information about unnamed persons

CRA is drafting a communique that will clarify that s. 231.1 is the primary information power used by CRA officials to request information, documents, access, and reasonable assistance; whereas the s. 231.2 power will be reserved for obtaining records of financial institutions, information on behalf of treaty partners, and information about unnamed persons.

The communique will clarify that CRA officials should explain in general terms, within the information-gathering correspondence or during meetings, the compliance issue and why the documentation and information sought may be relevant in determining the obligations and entitlements of a taxpayer.

The communique will also apply for purposes of the ETA, which has parallel provisions.

Neal Armstrong. Summary of 28 May 2025 IFA Roundtable, Q.4 under s. 231.1(1).