CRA is revising its procedures in response to BP Canada
In response to a question on what is its policy on tax accrual working papers following BP Canada (which was not appealed based on a discomfort in seeking before the Supreme Court confirmation of an unfettered right to information), CRA indicated that its policy is to request only the information that it believes it requires, with its focus being on determining what the taxpayer has done (as contrasted apparently with seeking evidence of the taxpayer’s concerns about what it did). CRA has set up a committee and is revising its procedures. If the taxpayer receives an unreasonably burdensome request, it should contact a senior large case manager or TSO assistant director.
Neal Armstrong. Summary of 20 November 2017 CTF Annual Conference - CRA Panel on Issues in the Administration and Enforcement of the ITA, Q.11 under s. 231.1(1)(d).