Privilege and Confidentiality in a CRA Audit

Course Price: $59.99

Number of PD hours: 1.0

Online - Recorded - Available


As the first point of contact in a CRA audit, accountants are uniquely positioned to shape the narrative and manage the scope of a client’s audit. While most accountants are aware that privileged documents do not need to be disclosed to a CRA auditor, the practice of identifying and asserting privilege is often underutilized. In practice, it can be challenging to determine when legal privilege applies but the ability to do so is a vital gatekeeping skill. Overzealous disclosure can inadvertently expand an audit to include other years, other taxpayers and, ultimately, other grounds for potential re-assessments.

This one hour course  will familiarize attendees with the fundamentals of privilege and how it can streamline an audit and add value for your clients. Topics include:

·         Understanding the difference between “privileged” and “confidential” documents

·         How to identify items commonly requested at audit that are protected by privilege

·         How to know and what to do if privilege has been waived

·         When is an accountant’s work privileged?

·         Recent developments in the case law 


Stephanie D'Amico LL.B

Stephanie is a member of the firm’s Tax Group. She is developing a broad practice that encompasses advocacy and advisory support for clients involved in tax disputes, including proceedings under the Income Tax Act, the Excise Tax Act, the Employer Health Tax Act, the Land Transfer Tax Act, and other provincial taxation regimes.

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