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ARTICLE · 21 OCTOBER 2026

Tax Audits: Best Practices For Recipients Of Third-Party RFIs

Blake, Cassels & Graydon LLP
Blake, Cassels & Graydon LLP
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Blake, Cassels & Graydon LLP

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Requests and requirements for information (RFIs) are among the Canada Revenue Agency’s (CRA) most powerful audit tools. Recent legislative proposals would introduce new administrative penalties for non-compliance with RFIs, increasing the consequences for recipients.

CanadaTax
Donya Ashnaei
Donya Ashnaei
Pooja Mihailovich
Pooja Mihailovich
Erich Schultze
Erich Schultze
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Requests and requirements for information (RFIs) are among the Canada Revenue Agency’s (CRA) most powerful audit tools. Recent legislative proposals would introduce new administrative penalties for non-compliance with RFIs, increasing the consequences for recipients.

A recent decision of the Federal Court of Appeal in Canada (National Revenue) v. Zeifmans LLP provides helpful guidance for recipients of third-party RFIs in assessing their obligations.

Here are five best practices in the current environment:

  1. Assess whose information is being requested. If the CRA is seeking information relating to persons explicitly named in the RFI (named persons), production of the information is likely required to the extent it is within the power, possession or control of the recipient, subject to privilege and other applicable protections. If the CRA seeks information related to persons that are not explicitly named (unnamed persons), further analysis is required.

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