http://decisions.fct-cf.gc.ca/site/fc-cf/decisions/en/item/64697/index.do 
Minister of National Revenue v. Vallelonga[1] (November 14, 2013) 1155 was a contempt proceeding in the Federal Court for breach of a compliance order under section 231.7 of the
Income Tax Act:[2]
231.7
Compliance order
(1) On summary application by the Minister, a judge may, notwithstanding subsection 238(2), order a person to provide any access, assistance, information or document sought by the Minister under section 231.1 or 231.2 if the judge is satisfied that
(a) the person was required under section 231.1 or 231.2 to provide the access, assistance, information or document and did not do so; and
(b) in the case of information or a document, the information or document is not protected from disclosure by solicitor-client privilege (within the meaning of subsection 232(1)).
Notice required
(2) An application under subsection (1) must not be heard before the end of five clear days from the day the notice of application is served on the person against whom the order is sought.
Judge may impose conditions
(3) A judge making an order under subsection (1) may impose any conditions in respect of the order that the judge considers appropriate.
Contempt of court
(4) If a person fails or refuses to comply with an order, a judge may find the person in contempt of court and the person is subject to the processes and the punishments of the court to which the judge is appointed.
Appeal
(5) An order by a judge under subsection (1) may be appealed to a court having appellate jurisdiction over decisions of the court to which the judge is appointed. An appeal does not suspend the execution of the order unless it is so ordered by a judge of the court to which the appeal is made.
The facts were not complex. There had been a compliance order:
[5] The Applicant then sought an Order from this Court on May 7, 2012. By Order (the “Compliance Order”), this Court ordered the Respondent to comply with the Applicant’s Request for Information. More specifically, the Court stated the following:
THIS COURT ORDERS pursuant to section 231.7 of the
Income Tax Act that the respondent shall comply with the notice issued by the Minister and shall forthwith, and in any event not later than 30 days after being served with this Order, provide the Information and Documents to a Canada Revenue Agency officer acting under the authority conferred by the Income Tax Act or such other person designated.
When the taxpayer failed to comply with the order there was a Show Cause order issued:
[8] On February 18, 2013, Madam Prothonotary Mireille Tabib, satisfied of the existence of a prima facie case of contempt committed by the Respondent, granted an Order (the “Show Cause Order”) pursuant to section 467 of the Rules which directed the Respondent to appear before this Court on April 15, 2013, and to be prepared to present any defense that he may have to the charge that he is guilty of contempt of Court for breaching the Compliance Order. More specifically, the Court stated the following:
THIS COURT ORDERS THAT:
1. The Respondent appears before a Judge of the Federal Court in the City of Montreal in the province of Quebec on Monday, the 15th day of April, 2013 at 9:30 a.m. to hear proof of the following acts, purportedly committed by him, with which he is charged herein and to be prepared to present any defence that he may have to the charge that he is guilty of contempt of this Honourable Court for breaching the Order of the Honourable Justice Simon Noël dated May 7, 2012, that is:
a)by Order of the Federal Court dated May 7, 2012 (the “Compliance Order”) the Respondent was ordered to provide the Information and Documents sought by the Applicant pursuant to subsections 231.2 and 231-7 of the Income Tax Act;
b) the Compliance Order was personally served on the Respondent on May 15, 2012; and
c)the Respondent has not provided the Information and Documents as required by the Compliance Order within the thirty (30) days stipulated in the Order, or at all.
THIS COURT FURTHER ORDERS THAT:
1. Service of this Show Cause Order on the Respondent shall include copies of:
a)the Affidavit of Siradiou Barry, sworn February 11, 2013;
b) the Affidavit of Jean Caron, sworn May 15, 2012;
c)the Order of the Honourable Justice Simon Noël, dated May 7, 2012.
The respondent was unsuccessful in persuading the court that he was ready to purge his contempt:
[17] The Applicant did not testify and chose to produce his submissions by way of a written document which serves no purpose with regard to the charges against him. However, he indicated that he understood the matter and that he would produce the Information and Documents requested in the 60 days following this Order.
…
[24] The evidence presented to the Court is to the effect that the Respondent was personally made aware of the Compliance Order requiring him to disclose the cited Information and Documents, that he has failed to do so in the allotted time, and that he has yet to do it, despite having been served with the Compliance Order and the Show Cause Order. While this Court recognizes the fact that the Respondent has undertaken to provide the Applicant with the requested Information and Documents, this situation in no way changes the reality of the present matter: contempt of Court indeed occurred. Therefore, considering such evidence, this Court is satisfied beyond a reasonable doubt that the Respondent is guilty of contempt of Court.
In addition to a fine of $3,000 and a cost award of $14,731.59 the court ordered the respondent imprisoned for a maximum of three years if he failed to honour the compliance order within 60 days:
[29] Thus, this Court concludes that given the circumstances of the case the Applicant is to pay a fine, to pay the Applicant’s costs and to comply with this Court’s Compliance Order dated May 7, 2012 by providing the Information and Documents listed in the Applicant’s Requirement for Information dated November 16, 2011 according to the terms of this present Order.
ORDER
THIS COURT ORDERS that:
1. The Respondent is guilty of contempt of Court and shall pay a fine of $3,000 and $14,731.59 in solicitor-client costs to the Applicant, including the costs of the contempt hearing, within 60 days from the date of service of this Order. Failure to pay the fine or the costs, or both, shall result in the imprisonment of the Respondent under the conditions set out in paragraphs 2 and 3, below.
2. The Respondent shall not be imprisoned for failure to pay the fine or costs, or both, if, within 30 days from the date of service of this Order, the Respondent arranges with the Applicant for an oral examination under oath and provides evidence satisfactory to the Court that the Respondent is not able to pay the fine or the costs, or both, or that he needs an extended period of time to pay.
3. If the Applicant informs the Court by affidavit that either the fine or the costs, or both, have not been paid within 60 days from the date of service of this Order, and that the Respondent has not arranged with the Applicant for an oral examination under oath with respect to the Respondent’s ability to pay the fine or the costs, or both, the Court shall issue a warrant for the Respondent’s imprisonment for a maximum of 30 days or until such time as the Respondent pays the fine and the costs.
4. The Respondent shall provide the Information and Documents, as set out in the Compliance Order, within 60 days from the date of service of this Order, or provide the Applicant with an affidavit explaining why he is not able to provide the Information and Documents. Failure to provide said Information and Document shall result in the imprisonment of the Respondent under the conditions set out in paragraph 5, below.
5. If the Applicant informs the Court by affidavit that the Respondent has not, within 60 days of service of this Order, provided the Information and Documents and has not provided an affidavit explaining why he is not able to provide the Information and Documents,
this Court shall issue a warrant for the Respondent’s imprisonment for a maximum of three years or until such time as the Respondent complies with the Compliance Order.
6. The sentences set out in paragraphs 3 and 5 above are to run concurrently.
[Emphasis added]
It is clear that the Federal Court is taking compliance orders very seriously and that taxpayers should act accordingly when subject to such orders.
[1] 2013 FC
[2] R.S.C. 1985, c. 1 (5th Supp.), as amended.