Archive for Month: October

Tax advisor handing over client documents during a CRA investigation into tax records and information.

Why Accountants Have No Solicitor-Client Privilege: Minister of National Revenue v KPMG Canada LLP and the CRA’s Power to Compel Tax Advisors to Produce Client Documents and Information

Overview: Accountant Privilege, CRA Compliance Orders, and the Income Tax Act The Federal Court’s June 12, 2026 decision in Minister of National Revenue v KPMG Canada LLP, T-139-26, is a significant ruling on the limits of privilege assertions by third-party tax advisors in the context of CRA audits. The...

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Confidential business records protected during a Canadian tax dispute involving the CRA and Tax Court discovery.

How to Invoke ‘Confidentiality Orders’ to Safeguard Competitive Information at the Discovery Stage: Lessons From Canada v. CAE Inc. for Canadian Businesses Fighting the CRA

Overview: Protecting Sensitive Business Records In Tax Court: Lessons From Canada v. CAE Inc., 2026 FCA 138 Litigating against the Canada Revenue Agency (CRA) often means handing over sensitive business records, some of which a company would never want a competitor, or the public, to see. The Federal Court...

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