The Canada Revenue Agency (CRA) is currently engaged in a court battle with Shopify over access to the transaction records and sales data of its merchants. The CRA’s request, known as an unnamed persons requirement (UPR), seeks detailed information across 16 categories, including the identities and bank details of Shopify clients.
Shopify has resisted these demands, with COO Kaz Nejatian criticizing the move as creating a “backchannel.” Shopify’s legal defense argues that the requested data is not readily available and gathering it would be labor-intensive. The CRA has previously succeeded in similar UPR cases against other tech platforms to verify tax compliance.
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