After finding that a demand under former s. 231(3) would constitute a "seizure" for purposes of s. 8 of the Charter because the compelled production of documents pursuant to s. 231(3) very well could extend to information and documents to which the taxpayer had a privacy interest in need of protection under s. 8 of the Charter, Wilson J. went on to find that such a seizure did not entail an unreasonable intrusion on the taxpayer's privacy interest. She stated (at p. 6251):
"s.231(3) provides the least intrusive means by which effective monitoring of compliance with the Income Tax Act can be effected. It involves no invasion of a taxpayer's home or business premises. It simply calls for the production of records which may be relevant to the filing of an income tax return. A taxpayer's privacy interest with regard to these documents vis-รก-vis the Minister is relatively low."