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BP Canada: Uncertain Tax Positions and the Importance of Maintaining Privilege
In its recent decision in Minister of National Revenue v. BP Canada Energy Company, the Federal Court of Canada considered the Minister’s ability to compel BP to provide its tax accrual working papers pursuant to the Minister’s inspection powers in subsection 231.1(1) of the Income Tax Act. The decision in favour of the Minister signals a substantial change to the audit process and may require modifications to the way in which corporate taxpayers analyse their uncertain tax positions.