Imperial Tobacco - Tax Court finds that privilege was lost when emails of an Osler tax lawyer were sent to PWC Australia

D'Arcy J found that solicitor-client privilege was lost when emails of an Osler tax lawyer addressed primarily to an individual at the Canadian taxpayer's UK parent were also sent to PWC Australia.  Having regard to the Susan Hosiery principle, the taxpayer was unable to establish "that PWC Australia's role, whatever it was, extended to any function which could be said to be integral to the solicitor-client relationship."

Scott Armstrong.  Summary of Imperial Tobacco Canada Ltd. v. The Queen, 2013 TCC 144 under s. 232 - solicitor-client privilege.