Stack v. The King, 2024 TCC 137 -- attach -- Solicitor-Client Privilege
legal advice transmitted by a financial planning firm to an accountant for the taxpayers was protected by privilege
Solicitor-Client Privilege
Coopers Park Real Estate Development Corporation v. The King, 2024 TCC 122 -- attach -- Solicitor-Client Privilege
advice provided by KPMG was not protected by privilege despite KPMG’s label as the client’s agent in law firm dealings
Élisabeth Robichaud, Marie-Emmanuelle Vaillancourt, "An Avoidable Threat to the Protection of Solicitor-Client Privilege", Perspectives on Tax Law & Policy, Vol. 4, No. 3, September 2023, p. 11 -- attach -- Solicitor-Client Privilege
Gaudreau v. The King, 2023 TCC 115 -- attach -- Solicitor-Client Privilege
no accountant-client privilege
632738 Alberta Ltd. v. The King, 2023 TCC 117 -- attach -- Solicitor-Client Privilege
company could refuse to not disclose its reasons for engaging in transactions on grounds of privilege
BMO Nesbitt Burns inc. v. Canada (National Revenue), 2023 FCA 43 -- attach -- Solicitor-Client Privilege
providing a full spreadsheet would not breach privilege
Commissioner of Taxation v PricewaterhouseCoopers , [2022] FCA 278 -- attach -- Solicitor-Client Privilege
privilege available for communications which were predominantly legal advice made by lawyer members of multi-disciplinary firm
Canada (National Revenue) v. BMO Nesbitt Burns Inc., 2022 FC 157, aff'd 2023 FCA 43 -- attach -- Solicitor-Client Privilege
spreadsheet did not communicate the very legal advice given
The Civil Aviation Authority v Jet2.Com Ltd, R. (on the Application of), [2020] EWCA Civ 35 -- attach -- Solicitor-Client Privilege
dominant purpose test applied to determining whether privilege applies to emails sent to both lawyers and executives/disclosure of one email was not a waiver of privilege on other emails
R. v. Morris, 2019 QCCQ 7635 -- attach -- Solicitor-Client Privilege
no waiver of privilege when ARQ auditor disclosed part of a legal opinion in her audit report
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