The OBA tax section sponsored a good session today on “Best Practices for Managing the Flow of Information to and from the Canada Revenue Agency”. A couple of interesting tidbits that came out:
1. Some folks at the CRA seem to think they can summon taxpayers to a TSO to answer questions in the context of an audit. It was suggested at the seminar that the CRA does not have this power. Paragraph 231.1(1)(d) of the Income Tax Act does require taxpayers to answer questions, but it does not give the CRA the power to issue anything like a subpoena (a legal process requiring a person to appear at a certain place at a particular time to provide testimony).
2. The CRA has published form RC378, which gives some helpful pointers on how to make an ATIP request (request for information) to the CRA.
