Steve Suarez, “FCA To Hear Atlas Tube Appeal” 27:12 Canadian Tax Highlights (December 2019), discusses Canada (National Revenue) v. Atlas Tube Canada ULC, 2018 FC 1086. The Federal Court held that an accounting firm’s due diligence report on the tax attributes and exposures of a target corporation was not privileged and was subject to disclosure to the CRA. The taxpayer has appealed the decision. The author argues that the Federal Court judge made a number of errors of law in arriving at its decision.
