Tax Court of Canada Rules (General Procedure)

105 (1) Unless the parties otherwise agree, or the Court otherwise directs, the person to be examined shall bring to the examination and produce for inspection,

• (a) on an examination for discovery, all documents as required by subsection 85(3), and

• (b) on all other examinations, such documents as may be required by subsection 105(3).

(2) Where a person admits, on an examination, that he or she has possession or control of or power over any other document that relates to a matter in issue in the proceeding and that is not privileged, the person shall produce it for inspection by the examining party forthwith, if the person has the document at the examination, and if not, within ten days thereafter, unless the Court directs otherwise.

(3) The notice to attend for examination or subpoena may require the person to be examined to bring to the examination and produce for inspection,

• (a) all documents and things relating to any matter in issue in the proceeding that are in that person’s possession, control or power and that are not privileged, or

• (b) such documents or things described in paragraph (a) as are specified in the notice or subpoena,

unless the Court directs otherwise.