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Canadian Supreme Court Holds Tax Information Requests Unconstitutional where Solicitor-Client Privilege Applies

|Approved Changes|Canada
Canada

On 3 June 2016, the Supreme Court of Canada issued two decisions concerning the constitutionality of demands for information and documents sent to lawyers and notaries by the Canada Revenue Agency (CRA) under Canada’s Income Tax Act (Act) as it relates to solicitor-client privilege. The cases involved legal action brought on by the Quebec Chamber of Notaries against CRA requests for information from various notaries and an appeal by an Alberta-based lawyer against a CRA request for client doc…

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