Expert Analysis

Federal Court of Appeal clarifies rules for CRA requests for unnamed persons

By Cris Best ( September 29, 2026, 2:03 PM EDT) -- The lengthy decision in Canada (National Revenue) v. Zeifmans LLP, 2026 FCA 147 (Zeifmans) in part involves a detailed analysis of the legal concepts of abuse of process and improper collateral attack as well as the relevant decisions in Canada (Customs and Revenue Agency) v. Artistic Ideas Inc., 2005 FCA 68 (Artistic Ideas) and Redeemer Foundation v. Minister of National Revenue, 2008 SCC 46 (Redeemer)....