The Tax Court of Canada has confirmed the absence of any accountant-client privilege in the country''s tax law and ordered the production of an accountant''s client-related documents (Coopers v Canada Revenue Agency, 2024 TCC 122). It dismissed most of the taxpayer''s claim for solicitor-client privilege, including a partially redacted engagement letter; letters and emails; strategy documents with diagrams and handwritten notations; and documents that contained the "hallmarks of a legal opinion" but fell outside the scope of the engagement letter from the taxpayer to its lawyers. However, it agreed that solicitor-client privilege applies where an accountant acts as a representative or agent for a client in obtaining legal advice from a solicitor.
Source：【2024/10/03 Miller Thomson】