Oral questioning on audit

Canada (National Revenue) v Cameco Corporation, 2019 FCA 67, aff’g 2017 FC 763, held that the CRA, on an audit, cannot compel a taxpayer to submit to oral questioning. Of course, a refusal to answer oral questions can lead to the Minister drawing an adverse inference. (Does the Minister ever do otherwise?) Ashvin Singh, “CRA Cannot Require Oral Interviews” Canadian Tax Focus 9:2 (May 2019).

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