Thompson v. Canada (National Revenue), 2013 DTC 5146 [at at 6296], 2013 FCA 197, rev'd 2016 SCC 21 -- summary under Solicitor-Client Privilege

By services, 28 November, 2015

The Minister served a Requirement on the appellant, a lawyer, to disclose information including a detailed accounts receivable listing. The appellant argued that solicitor-client privilege protected that information, chiefly because it disclosed client names and other personal information. In affirming the trial judge's position that privilege did not apply, the Trudel JA noted that:

  • privilege belongs to the client, and can only be asserted or waived by the client through his or her informed consent (para. 39);
  • client names and addresses are not privileged per se - personally identifying information is only privileged if the client's identity constitutes the foundation of the retainer or the essence of the consultation (para. 41);
  • the burden lies with the party claiming privilege (para. 49); and
  • the Minister was not seeking the information contained in statements of account, which may be privileged (paras. 57-58).
Topics and taglines
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clients' names not generally privileged
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Drupal 7 entity ID
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