Canada (Minister of National Revenue) v. Singh Lyn Ragonetti Bindal LLP, 2005 DTC 5703, 2005 FC 1538 -- summary under Solicitor-Client Privilege

CCRA was audited the respondents' accounting records in connection with its review of an alleged scheme involving the extraction of funds from RRSPs without payment of income tax, and served a requirement under s. 231.2(1) requiring the respondents trust account records pertaining to transfers from nine trust companies. In finding the privilege did not attach to these records, Mosley J. affirmed the proposition "that solicitor-client privilege does not extend to records of financial transactions directed through solicitor's trust accounts as such records are evidence of an act or transaction rather than communications" (p. 5705).