KPMG – Federal Court of Canada finds that s. 231.2(3) overrides the CPA duty of maintaining client confidentiality

KPMG LLP sought to quash an order that authorized CRA to impose a requirement on it pursuant to s. 231.2(3) to disclose confidential information respecting unnamed clients who had participated in the KPMG “Offshore Company Structure” – on the grounds that the CPA Code of Professional Conduct prohibited disclosure of confidential client information. In dismissing the motion, Crampton CJ stated that “the language of s. 231.2(3)… is clear and overrides the general confidentiality rule imposed by Rule 208 of the Code.”

Neal Armstrong. Summary of Canada (National Revenue) v. KPMG LLP, 2016 FC 1322 under s. 231.2(3).