Privilege
Tax Court of Canada issues a comprehensive ruling on privilege issues and the appropriate exercise of remedies to address deficient lists of documents
In a recent Tax Court of Canada ruling on a motion heard in Imperial Tobacco Canada Limited v. The Queen, 2013 […]
Could solicitor-client privilege be a hallmark of a reportable transaction under proposed s. 273.3 of the Income Tax Act?
Under proposed 237.3 of the Income Tax Act, a “reportable transaction” is an avoidance transaction that has two of three […]