The Canadian Minister of National Revenue (“Minister”) may, under subsection 231.2(3) of the Income Tax Act, R.S.C. 1985, c. 1 (5th Supp.) and subsection 289(3) of the Excise Tax Act, R.S.C. 1985, c. E-15, seek information from third parties in order to look for tax cheats. The request by the Minister is known…