Précis: Amdocs Canadian Managed Services Inc. (“Amdocs Canada”) is part of a multi-national group providing “software and related services to over 250 communication, media and entertainment services providers in over 80 countries” (para. [2]). In 2013 CRA commenced domestic, transfer pricing and foreign accrual property income audits of Amdocs Canada for its 2011 and 2012 taxation years. As part of the audits it issued a number of queries pursuant to paragraph 231.1(1)(a) of the Income Tax Act (the “Act”) (the audit power).
R. v. Amdocs Canadian - FCt: Court refused a compliance order for non-existent documentsPlus >