By Brian Kearl and Paige Donnelly ( November 29, 2024, 2:11 PM EST) -- In the course of a tax appeal, the taxpayer and the Canada Revenue Agency (CRA) have the right to inspect certain documents in the possession, control or power of the other party, provided they are relevant to any matter in question in the appeal (Rule 85 of the Tax Court of Canada Rules (General Procedure)). However, documents protected by solicitor-client privilege are exempt from this requirement. Generally, documents created by taxpayers’ accountants must be disclosed....