Canada (National Revenue) v. Fosty

Decided: 2026-10-20. Docket: T-3190-26. Citation: 2026 FC 1276 (CanLII). Taxation — Income Tax Act compliance powers — Compliance order — Income Tax Act, subs. 231.7(1), s. 231.1 — Whether Respondent was required to provide requested information and documents and complete worksheets — Non-compliance with CRA requests and refusal to cooperate — Compliance order conditions satisfied — Summary application granted | Evidence — Solicitor-client privilege — Disclosure in tax audit — Income Tax Act, subs. 231.7(1) — Whether requested information and documents are protected from disclosure by solicitor-client privilege — No reason to believe materials contain privileged communication — Privilege not established on the record — Compliance order issued | Procedure — Adjournment and service — Summary