http://decisions.fct-cf.gc.ca/fc-cf/decisions/en/item/109241/index.do 
Canada (National Revenue) v. Revcon Oilfield Constructors Incorporated (April 23, 2015 – 2015 FC 524, Mosley J.).
Précis: In 2013 CRA issued two requirements to Revcon Oilfield Constructors Incorporated (“Revcon”) for information requiring the taxpayer to produce materials in connection with a reorganization it undertook in 2011. When Revcon failed to produce the material CRA applied to the Federal Court for a compliance order pursuant to section 231.7 of the
Income Tax Act. Revcon asserted claims of solicitor-client privilege over most, if not all, of the material. The Federal Court ruled that while some of the material was privileged the bulk of it was not. It ordered that the non-privileged material be produced and awarded costs to CRA.
Decision: Revcon asserted solicitor-client privilege over material sought by CRA on a number o bases:
[6] First, privilege is claimed over items that would identify Law Firm X, an undisclosed law firm which was retained by the Respondent’s counsel for the purposes of the restructuring transactions being audited [the Law Firm X claim].
[7] Second, privilege is claimed over items which include “shorthand tax law language used by Law Firm X that describes the Transactions in a manner that could potentially be prejudicial to the Respondent’s interests” [the Nomenclature claim].
[8] Third, privilege is claimed over items which include Law Firm X’s opinion respecting the transactions or the work product of Law Firm X’s legal retainer [the Structuring claim].
[9] Fourth, privilege is claimed over items which were communications for the purpose of obtaining legal advice or assistance [the Legal Advice claim].
The Court summarily rejected the Law Firm X claim and the Nomenclature claim:
[25] The Respondent has provided me with no authority to support the proposition that the Law Firm X and Nomenclature claims are valid bases upon which to claim solicitor-client privilege. The idea that the identity of a law firm or lawyer retained by a client to provide tax planning advice is privileged finds no support in the law. It does not matter whether the law firm was retained “indirectly” by another firm directly retained by the client. A communication revealing the name of a law firm or lawyer – without anything else, such as actual legal advice – is not a confidential communication made for the purpose of receiving legal advice from a lawyer acting in a legal capacity. The name of a law firm, without more, is not protected by solicitor-client privilege. Nor is the revelation of shorthand tax language used by tax planning advisors.
Of the remaining claims the Court found communications between Revcon and its solicitors containing legal advice was privileged, including the contents of statements of account, but not a letter transmitting minute books.
As a result the Court allowed CRA’s application, with costs:
[45] The claims of privilege initially made by Mr Thiessen on behalf of the Respondent in meetings with CRA and reiterated by Mr Billesberger in his affidavit of August 29, 2014 were overly broad. The grounds advanced in support of the claims were largely unfounded and unsupported by any legal authority. This was made abundantly clear in the scant record submitted by the Respondent and in the oral representations of Mr Forer at the hearing on March 19, 2015.
[46] Accordingly, an Order shall issue requiring the Respondent to provide the information and documents requested by the Applicant within 30 days of service of a copy of the Order.