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ARTICLE · 08 AUGUST 2024

CRA Requests For Lawyers' Trust Ledgers

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Sakab Saudi Holding v. Saad Khalid (2024 ONSC 1601; under appeal), a recent civil litigation decision on solicitor-client privilege, may strengthen protections for lawyers...

CanadaTax
Stefan Case
Stefan Case
John Tobin
John Tobin
Jeremy Opolsky
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Sakab Saudi Holding v. Saad Khalid (2024 ONSC 1601; under appeal), a recent civil litigation decision on solicitor-client privilege, may strengthen protections for lawyers' accounting records if they are requested by the CRA, either from a taxpayer's lawyer or from the taxpayer directly in respect of records received from the lawyer (you can read our full analysis of the decision). The principle that emerges from the case is that any document that could reveal something about what transpired within the solicitor-client relationship—such as a road map of legal advice sought or given—is potentially privileged.

The plaintiffs in Sakab Saudi alleged that the defendants misappropriated billions of dollars and dissipated these funds around the world. The plaintiffs sought production of any lawyers' trust ledgers that showed funds sent, received, or held in trust for the defendants, arguing that this was necessary to determine where the defendants' assets were.

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