Tax Authorities Continue To Pursue Non-privileged Information
Canadian tax authorities continue to aggressively pursue taxpayer information, using the extensive powers granted to them under tax legislation. Sensitive communications with, and work product prepared by, accountants and other non-lawyers represent fertile ground for the Canada Revenue Agency. This was illustrated by the CRA’s success before the Federal Court of Canada in Minister of National Revenue v. BP Canada Energy Company, in June 2015, in forcing disclosure of the taxpayer’s list of uncertain […]