BP Canada – Federal Court compels production to CRA of taxpayer tax accrual working papers

Campbell J allowed the Minister's demand on BP Canada to produce unredacted copies of its tax accrual working papers (containing descriptions of all the material issues it knew of for which it had exposure).  CRA's position had always been that such papers are compellable, and the restraint with which it typically applies that policy is not binding.

Neal Armstrong. Summary of MNR v. BP Canada Energy Co., 2015 FC 714, under s. 231.1(1).