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ARTICLE · 23 MAY 2019

Be Careful What You Ask For: Limits On Oral Interviews Confirmed In Cameco

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MNR v Cameco Corporation, 2019 FCA 67 ("Cameco") was an unsuccessful appeal by the Crown of a failed compliance order application in the Federal Court ("FC").

CanadaTax
John Sorensen
John Sorensen
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Introduction

MNR v Cameco Corporation, 2019 FCA 67 ("Cameco") was an unsuccessful appeal by the Crown of a failed compliance order application in the Federal Court ("FC"). The issue was whether the Minister of National Revenue ("Minister") could compel Cameco employees to attend interviews and answer questions posed by CRA auditors. Although the Federal Court of Appeal ("FCA") unanimously upheld the ruling, two sets of reasons were issued, with different opinions on the merits of some of the FC`s guidance.

The Canada Revenue Agency ("CRA") conducted a transfer pricing audit of Cameco's 2010 through 2012 taxation years and sought interviews and oral answers to questions from 25 employees. Cameco offered to answer in writing, leading to the compliance order application to force in-person interviews. Readers will likely already know that a compliance order application is a court process under section 231.7 of the Income Tax Act (Canada) ("ITA")1 by which the

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