The Supreme Court of Canada held in the Jarvis decision that where the purpose of a tax inquiry is the determination of a penal liability, CRA auditors must warn the taxpayer in order to avoid infringing the Canadian Charter of Rights.
"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."