Saipem Luxembourg S.A. v. Canada (Customs and Revenue Agency), 2005 DTC 5348, 2005 FCA 218 -- summary under Subsection 231.6(5)

A requirement issued to the appellant to produce for the Agency's inspection the whole of its corporate records for two fiscal years (during which the appellant had employed one of its vessels in Canadian waters) was upheld. Although in enacting the reasonableness requirement in s. 231.6(5) "Parliament intended that a notice of requirement in respect of a foreign-based document must not only relate to a document which is relevant to the administration and enforcement of the Act but that it must also not be unreasonable" (p. 5354), here the requirement was not unreasonable in light of the Agency's wish to conduct an audit, which required it to be able to determine for itself that various books and records were not relevant to the appellant's Canadian tax liability.