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Under the previous policy, relatively low threshold CRA contact (such as a request for information or a broad educational letter) could be sufficient to disqualify a disclosure. The updated policy instead focuses on whether the CRA has initiated an audit or investigation - that is, whether significant compliance work on the specific issue has already begun.

The applicant applied for a job and was invited to complete a short tryout to assess his suitability. He was asked to perform a task using a hammer drill. While doing so, he injured his hand, dislocating fingers and requiring medical treatment, including splinting, physiotherapy, and temporary work restrictions.

The Federal Court’s June 12, 2026 decision in Minister of National Revenue v KPMG Canada LLP, T-139-26, is a significant ruling on the limits of privilege assertions by third-party tax advisors in the context of CRA audits.