Canada (National Revenue) v. Clark, 2012 DTC 5143 [at at 7324], 2012 FC 950 -- summary under Solicitor-Client Privilege

The respondent, a solicitor,was the sole shareholder of two corporations, and asserted solicitor-client privilege over various corporate records, which were predominantly accounting records. Snider J. found that the respondent had not met the burden of showing that any of the records were confidential communications between a client and a legal advisor. Although the respondent was a solicitor, the documents in question did not appear to contain any form of legal advice. They were merely evidence of a transaction, not a "communication" that attracts solicitor-client privilege.