Tax memo: TCDR alert: CRA policy on access to audit information at the proposal stage of an audit

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What to do to get access

Memo No. 2012-28

This Tax memo describes the Canada Revenue Agency’s (CRA's) policy on taxpayer access to CRA audit reports and other documents that support the issuance of a proposal letter. It suggests what to do if an auditor is reluctant to provide this information.

Information a CRA auditor used to create or support positions taken in a proposal letter must be made available to you upon an informal request, at the time the proposal letter is issued. This information can help you understand the basis of the proposal and the factual assumptions relied on by the auditor, especially when the basis is not adequately outlined in the proposal letter.

We understand that, in some cases, CRA auditors are reluctant to provide this information and refer taxpayers to the formal request process under the Access to Information Act (ATIA). Formal requests under the ATIA should be made only as a last resort, because they often involve significant delays, which can prevent the information from being available by the deadline for you to make representations to the proposal.

Read the memo to learn more.