ARTICLE · 23 JUNE 2022

Do Taxpayers Have To Physically Deliver Documents To CRA For Audit?

SpenceDrake Tax Law

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The applicant, CRA, first requested documents from the taxpayer years earlier, in May of 2014. They refused multiple times. At paragraph 40...

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As established in multiple decisions, includingCanada (National Revenue) v. Cameco Corporation,2019 FCA 67 (CanLII), Canada Revenue Agency ("CRA") has the authority to compel a taxpayer to "provide" the books and records they wish to audit. But what is the scope of "provide"?

The Federal Court of Canada was tasked with determining this inCanada (National Revenue) v. Montana,2019 FC 900 (CanLII) [Montana]. According to the Federal Court at paragraph 18, the issue triggering a multi-year and multi-hearing dispute leading to the Applicant's motion "appears to be simple at first glance: when ordered ""to provide"" documents to the CRA, must they simply be made available by the taxpayer, or must the taxpayer physically deliver them to the auditors?".

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