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Published: March 6, 2020

Last Updated: October 25, 2021

In order to properly deal with most CRA income tax problems, it is essential to obtain the complete file that CRA has. CRA records including internal audit reports are all available by way of an application under the Access to Information and Privacy program. In the case of an ongoing audit certain parts of the the report may be redacted. To be eligible to submit a request under the Access to Information Act or the Privacy Act, the taxpayer must be a Canadian citizen, a permanent resident of Canada or an individual or corporation currently present in Canada. One of the first steps carried out by our Montreal income tax litigation lawyers in resolving any income tax dispute, including income tax audits, income tax appeals or income tax collections files, is to submit an ATIP request on behalf of the taxpayer. We specify the income tax issues and request that CRA provide us with the complete file related to those issues, including reports and correspondence. In the case of CRA collections files we also ask for a complete accounting of the income tax debt. Whenever a Canadian taxpayer has a dispute with CRA it is imporant for his Toronto income tax lawyer to file an ATIP request.


"This article provides information of a general nature only. It is only current at the posting date. It is not updated and it may no longer be current. It does not provide legal advice nor can it or should it be relied upon. All tax situations are specific to their facts and will differ from the situations in the articles. If you have specific legal questions you should consult a lawyer."

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