Canada: CRA GAAR committee documents compelled - Superior Plus Corp v the Queen

Abstract

The Tax Court of Canada recently considered a taxpayer's entitlement to access records and information during the examination for discovery process regarding the Canada Revenue Agency (CRA) decision to apply the general anti-avoidance rule (GAAR). In its decision, the Tax Court of Canada emphasised that the relevance threshold at the discovery stage is low. The court ultimately ordered that a majority of the refused questions be answered, and that a majority of the refused documents be produced in un-redacted form.