Karia v. Canada (Minister of National Revenue), 2005 DTC 5282, 2005 FC 639 -- summary under Interpretation Bulletins, etc.

A statement in Information Circular IC00-1R, that a disclosure will be treated as voluntary if the taxpayer initiated it without knowledge of an audit or investigation by the CCRA or an authority with which the CCRA had an information exchange agreement, was treated by Strayer D.J. as a promise by the CCRA, with the result that a breach of that promise to the taxpayer resulted in the Minister being estopped from treating a disclosure by the taxpayers as not being voluntary.