Cases, Recent Policy Define Disclosure Landscape in Canada

In the United States, recent events such as the Supreme Court’s refusal to consider Textron’s case over tax accrual work papers and an Internal Revenue Service draft schedule on which large taxpayers will have to list their uncertain tax positions point to an ever-growing ability on the part of the government to seek information about taxpayers.

In Canada, practitioners say the same is true. Although the country has no parallel to the uncertain tax position schedule under development at the IRS, it recently released a policy on acquiring information that asserts broad access to taxpayer documents. In addition, several court cases affirm the Canada Revenue Agency’s ability to obtain information from a company’s accountant or its affiliates, as well as about entities not subject to the current audit. Enjoying this article? To continue reading you need to take out a FREE trial to the Transfer Pricing Library.




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