90 C.R. - Q62

It is RC's general practice to request accountants to produce specific working papers for examination where they can reasonably be considered an extension of the client's records.

When there is good reason to believe that tax planning documentation which is relevant to determining the intention of the taxpayer is in the possession of the accountant, and it has not been provided after informal and formal written requests, a requirement under s. 231.2 may be issued.