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Published: July 11, 2023

The question, however, is whether legal privilege also applies to a document that implements, or that was prepared in accordance with, the legal advice in the tax memorandum. This very issue lay at the centre of BMO Nesbitt Burns Inc. v Canada, 2023 FCA 43. The BMO Nesbitt Burns decision draws a distinction between legal advice and end-product documents.

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"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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