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FEDERAL INCOME TAX - Administration and enforcement - Audit - Requirement to provide documents or information - Compliance order - Appeals

Wednesday, May 10, 2017 @ 9:13 AM  

Appeal by BP Canada Energy Company (BP) from an order compelling the production of internal accounting documents. The Minister was conducting ongoing audits of BP. It sought production of certain tax accrual or tax reserve working papers and Issues Lists for the purpose of the audit. The records were prepared by BP's in-house staff and listed uncertain tax positions that could potentially give rise to contingent liabilities. The Minister issued a demand pursuant to s. 231.1(1) of the Income Tax Act requiring BP to provide the...