On 18 February 2013 the Minister of national Revenue moved ex parte for an order under section 231.2(3) of the Income Tax Act, authorizing him to impose on KPMG LLP a requirement to provide information relating to certain of its unnamed clients, including their identities, and documentation relating to their participation in an offshore company tax structure.
KPMG moved for an order quashing the ex parte order. It sought a declaration that the sections of the Income Tax Act which authorized the order were of no force or effect because they unjustifiably infringe the protections of life, liberty and security . . . [more]