The Resource Canada Revenue Agency declares open season on taxpayer information

Canada Revenue Agency declares open season on taxpayer information

Label
Canada Revenue Agency declares open season on taxpayer information
Title
Canada Revenue Agency declares open season on taxpayer information
Creator
Subject
Language
eng
Summary
The Canada Revenue Agency's provocative (and successful) effort to obtain the taxpayer's tax accrual working papers in Minister of National Revenue v. BP Canada Energy Co. indicates that the CRA now considers those materials to be fair game for use as an audit roadmap for tax purposes. Unless overturned, the decision will leave a taxpayer's subjective assessment of its uncertain tax positions (and any other tax analysis) completely exposed to demands for disclosure from Canadian tax authorities, unless protected by lawyer-client privilege. Those preparing that kind of confidential and sensitive tax analysis would be well advised to do so within the scope of lawyer-client privilege, which is not lost under Canadian law when disclosure is made to the taxpayer's external auditors for the limited purpose of completing its financial statements
Citation source
In: Tax notes international. - Falls Church. - Vol. 79 (2015),
http://library.link/vocab/creatorName
Suarez, S
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • case law
  • taxpayer rights
  • professional privilege
  • disclosure
Label
Canada Revenue Agency declares open season on taxpayer information
Instantiates
Publication
Label
Canada Revenue Agency declares open season on taxpayer information
Publication

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