Canada (National Revenue) v. Atlas Tube Canada ULC, 2018 FC 1086
| Jurisdiction | Federal Jurisdiction (Canada) |
| Citation | 2018 FC 1086 |
| Court | Federal Court (Canada) |
| Date | 05 November 2018 |
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7 practice notes
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Canada (National Revenue) v. Ghermezian, 2022 FC 236
...(see Redhead Equipment Ltd v Canada (Attorney General), 2016 SKCA 115 at para 31; Minister of National Revenue v Atlas Tube Canada ULC, 2018 FC 1086 at para 32). [22] However, the location of the burden becomes more nuanced in connection with particular defence arguments raised by the Respo......
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Canada (National Revenue) v. Ghermezian, 2022 FC 1010
...(see Redhead Equipment Ltd v Canada (Attorney General), 2016 SKCA 115 at para 31; Minister of National Revenue v Atlas Tube Canada ULC, 2018 FC 1086 at para 32). [36] At the hearing of the applications, the Respondents raised limited privilege arguments in relation to particular language in......
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CRA's Power To Compel Taxpayers To Disclose Uncertain Tax Positions Affirmed
...outset in order to be best positioned to claim privilege over due diligence reports when CRA seeks to compel their production. Footnotes 1 2018 FC 1086 [Atlas 2 RSC 1985, c 1 (5th Supp) [ITA]. 3 2017 FCA 61. About BLG The content of this article is intended to provide a general guide to the......
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Can The CRA Force A Taxpayer To Provide Any Document During A GST/HST Audit?
...the CRA a document, does so. Recently, the Federal Court of Canada issued a decision, Canada (National Revenue) v. Atlas Tube Canada ULC, 2018 FC 1086 (November 11, 2018) which addressed the issue of production of a requested document. In this case, the Minister of National Revenue (the Min......
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3 cases
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Canada (National Revenue) v. Ghermezian, 2022 FC 236
...(see Redhead Equipment Ltd v Canada (Attorney General), 2016 SKCA 115 at para 31; Minister of National Revenue v Atlas Tube Canada ULC, 2018 FC 1086 at para 32). [22] However, the location of the burden becomes more nuanced in connection with particular defence arguments raised by the Respo......
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Canada (National Revenue) v. Ghermezian, 2022 FC 1010
...(see Redhead Equipment Ltd v Canada (Attorney General), 2016 SKCA 115 at para 31; Minister of National Revenue v Atlas Tube Canada ULC, 2018 FC 1086 at para 32). [36] At the hearing of the applications, the Respondents raised limited privilege arguments in relation to particular language in......
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Enache v. Canada (Citizenship and Immigration), 2019 FC 182
...to make a decision on whether the second letter is privileged. In a recent decision, Canada (National Revenue) v Atlas Tube Canada ULC, 2018 FC 1086 at paras 11-13, in which the parties adopted a similar approach involving a document over which there was a disputed claim to solicitor-client......
4 firm's commentaries
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CRA's Power To Compel Taxpayers To Disclose Uncertain Tax Positions Affirmed
...outset in order to be best positioned to claim privilege over due diligence reports when CRA seeks to compel their production. Footnotes 1 2018 FC 1086 [Atlas 2 RSC 1985, c 1 (5th Supp) [ITA]. 3 2017 FCA 61. About BLG The content of this article is intended to provide a general guide to the......
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Can The CRA Force A Taxpayer To Provide Any Document During A GST/HST Audit?
...the CRA a document, does so. Recently, the Federal Court of Canada issued a decision, Canada (National Revenue) v. Atlas Tube Canada ULC, 2018 FC 1086 (November 11, 2018) which addressed the issue of production of a requested document. In this case, the Minister of National Revenue (the Min......
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Be Careful With Sensitive Tax Information!
...including sensitive tax information should consult with their tax lawyer to determine what can be protected and how to do so. Footnotes 1 2018 FC 1086. 2 [1980] 1 SCR 3 Redhead Equipment Ltd v Canada, 2016 SKCA 115, at para 45. The content of this article is intended to provide a general gu......
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FCA To Hear Atlas Tube Appeal
...case of Canada (National Revenue) v. Atlas Tube Canada ULC (2018 FC 1086) involves a number of interesting issues surrounding a tax diligence report prepared by an accounting rm for a potential purchaser of a target corporation. The report contained information on the tax prole and attribut......