CRA considers that in some circumstances it can require a taxpayer to disclose its uncertain tax positions
CRA indicated that it can seek the production of tax accrual working papers, provided that the request for such records is relevant to specific risks or items under audit, and it uses restraint in seeking the information. Factors considered before making such a request include the existence of large unexplained tax reserves.
CRA considers that (consistent with Atlas Tube) it may, in some circumstances, request a list from the taxpayer of its uncertain tax positions. Provided all relevant facts and transactions are included in the taxpayer’s uncertain tax positions, exclusions of the related advice and analysis may be accommodated. CRA recognizes the principle in BP that taxpayers are not required to self-audit.