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Published: April 16, 2020

Last Updated: May 21, 2020

The Federal Court of Canada decided recently in BP Canada Energy Company v. Minister of National Revenue (2015 FC 714), that CRA could force a taxpayer to turn over its list of uncertain tax positions (UTPs), which are judgment calls the taxpayer has made in completing its tax returns and is required to comply as part of an audit. This case marks a change in the policy of CRA which in the past has not requested a list of UTPs and is the first time that the CRA has gone to court to compel a taxpayer to turn over its UTP analysis of potential tax exposures to allow the CRA an audit roadmap. The decision will likely be appealed to the Federal Court of Appeal.


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