Question 1
What is the status of CRA’s study on this matter?
Response 1
A submission by the Canadian Institute of Chartered Accountants (“CICA”) had set out certain concerns, as well as an analysis of how other tax administrations deal with this issue. The CICA suggests that the CRA adopt a policy of restraint in requesting working papers, specifically working papers dealing with the analysis of the tax provision and/or the tax liability for both current and future income taxes as well as audit working papers and tax advice to clients. They advised that they would be considering their position based on our meeting, and would be providing further comments in June 2005. At this point, however, we have received no further comments from them. We also met with CGA-Canada for input and their primary interest was privilege.
Question 2
Can the CRA provide an update further to the CICA submission?
Response 2
At this point, we have considered their submissions and have met with other areas within CRA to discuss the above policy for consistency. We have finalized our consultations and are in the process of obtaining senior approval of the policy. The policy should be ready for release by the end of the calendar year 2005.