BP Canada Energy Company v. Canada (National Revenue), 2017 FCA 61

JurisdictionFederal Jurisdiction (Canada)
Subject MatterSTATUTES,CIVIL RIGHTS,CRIMINAL LAW,INCOME TAX,PRACTICE
Citation2017 FCA 61
CourtCourt of Appeal (Canada)
Date30 March 2017
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33 practice notes
  • High-Crest Enterprises Limited c. Canada,
    • Canada
    • Court of Appeal (Canada)
    • April 28, 2017
    ...& Pipelines Ltd. v. Alberta (Energy & Utilities Board), 2006 SCC 4, [2006] 1 S.C.R. 140; BP Canada v. Canada (National Revenue), 2017 FCA 61, [2017] 4 F.C.R. 355; Hryniak v. Mauldin, 2014 SCC 7, [2014] 1 S.C.R. 87; Trial Lawyers Association of British Columbia v. British Columbia (A......
  • BP Canada Energy Company c. Canada (Revenu national),
    • Canada
    • Court of Appeal (Canada)
    • March 30, 2017
    ...4 R.C.F. 355BP Canada EnErgy ComPany c. Canada (rEvEnu national)A-385-152017 FCA 61BP Canada Energy Company (Appellant)v.Minister of National Revenue (Respondent)andChartered Professional Accountants of Canada (Intervener)Indexed as: BP Canada energy ComPany v. Canada (natIonal revenue)Fede......
  • Canada (National Revenue) v. Dominelli, 2022 FC 187
    • Canada
    • Federal Court (Canada)
    • February 11, 2022
    ...the amounts responded by the taxpayer’” (Cameco at para 43, citing BP Canada Energy Co. v Minister of National Revenue, 2017 FCA 61 at para 82); iii. “The ITA only requires reasonable efforts to acquire requested documentation. If a document has been destroyed or is not......
  • Canada (National Revenue) v. Cameco Corporation, 2019 FCA 67
    • Canada
    • Court of Appeal (Canada)
    • April 3, 2019
    ...and ordinary meaning of paragraph 231.1(1)(a) and the decision of this Court in BP Canada Energy Co. v. Minister of National Revenue, 2017 FCA 61 (BP Canada), Cameco argues that the powers conferred under it are in respect of documented information, not any information. Finally, Cameco emph......
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17 cases
  • High-Crest Enterprises Limited c. Canada,
    • Canada
    • Court of Appeal (Canada)
    • April 28, 2017
    ...& Pipelines Ltd. v. Alberta (Energy & Utilities Board), 2006 SCC 4, [2006] 1 S.C.R. 140; BP Canada v. Canada (National Revenue), 2017 FCA 61, [2017] 4 F.C.R. 355; Hryniak v. Mauldin, 2014 SCC 7, [2014] 1 S.C.R. 87; Trial Lawyers Association of British Columbia v. British Columbia (A......
  • BP Canada Energy Company c. Canada (Revenu national),
    • Canada
    • Court of Appeal (Canada)
    • March 30, 2017
    ...4 R.C.F. 355BP Canada EnErgy ComPany c. Canada (rEvEnu national)A-385-152017 FCA 61BP Canada Energy Company (Appellant)v.Minister of National Revenue (Respondent)andChartered Professional Accountants of Canada (Intervener)Indexed as: BP Canada energy ComPany v. Canada (natIonal revenue)Fede......
  • Canada (National Revenue) v. Dominelli, 2022 FC 187
    • Canada
    • Federal Court (Canada)
    • February 11, 2022
    ...the amounts responded by the taxpayer’” (Cameco at para 43, citing BP Canada Energy Co. v Minister of National Revenue, 2017 FCA 61 at para 82); iii. “The ITA only requires reasonable efforts to acquire requested documentation. If a document has been destroyed or is not......
  • Canada (National Revenue) v. Cameco Corporation, 2019 FCA 67
    • Canada
    • Court of Appeal (Canada)
    • April 3, 2019
    ...and ordinary meaning of paragraph 231.1(1)(a) and the decision of this Court in BP Canada Energy Co. v. Minister of National Revenue, 2017 FCA 61 (BP Canada), Cameco argues that the powers conferred under it are in respect of documented information, not any information. Finally, Cameco emph......
  • Request a trial to view additional results
16 firm's commentaries
  • Department Of Finance (Canada) Releases Significant Draft Tax Legislation
    • Canada
    • Mondaq Canada
    • February 14, 2022
    ...tax treatments will effectively override the Federal Court of Appeal decision in BP Canada Energy Company v. Canada (National Revenue), 2017 FCA 61. Under the draft legislation, a corporation is required to file an information return with the CRA for a taxation year in which the following c......
  • Department Of Finance (Canada) Releases Significant Draft Tax Legislation
    • Canada
    • Mondaq Canada
    • February 14, 2022
    ...tax treatments will effectively override the Federal Court of Appeal decision in BP Canada Energy Company v. Canada (National Revenue), 2017 FCA 61. Under the draft legislation, a corporation is required to file an information return with the CRA for a taxation year in which the following c......
  • 2021 Federal Budget – Selected Tax Measures
    • Canada
    • JD Supra Canada
    • April 23, 2021
    ...proposed rules would overrule the unanimous Federal Court of Appeal decision in BP Canada Energy Company v. Canada (National Revenue), 2017 FCA 61, which held that tax accrual working papers were not “compellable ‘without restriction’”. It is also a rejection of several arguments advanced i......
  • No Routine Access By CRA To Tax Working Papers Rules The Federal Court Of Appeal
    • Canada
    • Mondaq Canada
    • April 18, 2017
    ...for every company that has audited financial statements. The court's decision in BP Canada Energy Company v. Canada (National Revenue), 2017 FCA 61 overturns the Tax Court of Canada ruling in the case, which held that BP Canada had to disclose multiple years' worth of tax working papers to ......
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