Canada Court Rejects Lawyer-Client Privilege for Tax Analysis

Canadian taxpayers can’t claim attorney-client privilege for advice on the tax implications of an acquisition, a Canadian court ruled.

The ruling indicates Canada’s tax agency will always seek access to tax-planning documents when it audits companies—so in order to protect them, they need to be carefully structured, lawyers told Bloomberg Tax.

Atlas Tube Canada ULC, a steel pipe and tube manufacturer, must provide the Canada Revenue Agency with a tax analysis prepared by an accounting firm because it wasn’t part of legal advice on its C$148 million ($112 million) acquisition of Lakeside Steel Inc., the Federal Court of ...