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ARTICLE · 04 NOVEMBER 2016

Maintaining Privilege For Cross-Disciplinary Tax Advising

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Redhead Equipment Ltd et al v. AG (Canada) provides a helpful summary of key principles governing solicitor-client privilege when lawyers and accountants are involved in transactional work and...

CanadaTax
John Sorensen
John Sorensen
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Redhead Equipment Ltd et al v. AG (Canada) (2016 SKCA 115) ("Redhead") provides a helpful summary of key principles governing solicitor-client privilege when lawyers and accountants are involved in transactional work and tax planning.

The background facts are as follows: 

  • Ownership and management:  Gary Redhead was the president of Redhead Equipment Ltd. ("REL") and president and director of the sole shareholder of REL, GLR Enterprises Inc. ("GLR"); GLR Consulting Ltd. ("GLR Consulting") was the sole shareholder of GLR; and Mr. Redhead was a shareholder, director and officer of related companies within the "Redhead Group".
  • Subject transactions:  REL restructured its business in 2009 and 2010 involving the creation of Redhead Equipment Partnership; REL, GLR and LCMR Enterprises Ltd. ("LCMR") commenced carrying on business in partnership as of January 1, 2010.

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