The Issue with Misconstrued Internal Statements - Learnings from ExxonMobil Canada Resources Company v. The King

It is well-known that the Canada Revenue Agency (the CRA) has broad audit and information gathering powers under the Income Tax Act (Canada). Subject to the existence of solicitor-client privilege, it is not uncommon for taxpayers to be required at the audit stage to disclose all corporate transaction books and records, including internal and external correspondence in respect of that transaction. In light of a potential CRA auditor reviewing such materials, it is essential that diligence and... By: Bennett Jones LLP