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NEW In-House Counsel | Insurance | Intellectual Property | Immigration | Natural Resources | Real Estate | Tax

Extending the privilege

Thursday, March 17, 2016 @ 8:00 PM | By Charles Marquette

Now more than ever taxpayers must be aware of how far the tax authorities will go after their internal information in the course of an audit.

Recently a Federal Court case held in favour of the Canada Revenue Agency to compel a corporate taxpayer to provide internally produced documentation that listed several uncertain tax positions for which it had taken reserves in its financial statements, thereby identifying to the agency where the taxpayer thought its highest risks were for loss in tax revenue on issues that...