Ted Citrome (Partner, Toronto) recently published an article in The Lawyer's Daily titled "Curtailing CRA audit power creates dilemma for taxpayers." In the article, Ted discusses the consequences resulting from the Federal Court of Appeal's decision in Canada v. Cameco Corporation 2019 FCA 67. The case, which involved Cameco refusing to allow the CRA to interview 25 of their employees as requested, causing the CRA to seek a summary judgement application for a compliance order, brought up the scope of the CRA's power to "inspect, audit or examine" a taxpayer's books and records.
"...the decision establishes firm boundaries to the CRA's audit power by holding that auditors cannot require taxpayers to be subjected to oral questioning." However, this also means that those who choose not to be subjected to questioning run the risk of having to refute the CRA's incorrect assumptions in court.