6 June 2019 CPTS Roundtable, 2019-0816111C6 -- summary under Subsection 231.2(1)

Does CRA accept the finding in Béarence that a taxpayer cannot be compelled to provide information in an alternate form if the taxpayer provided CRA with all the information relevant to computing its tax liability? CRA responded:

The Court found that the taxpayer had provided all the information in its possession and that the CRA could not compel a taxpayer to provide such information in another format. ...

Taxpayers have access to the information pertaining to their tax obligations and are expected to cooperate with CRA officials and to respond to reasonable requests for information. …

[T]he CRA policy is not at odds with the decision in … Béarence. CRA officials are expected to be reasonable in their requests for the information and documentation.

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