Issues:

1. Disclosure of Spreadsheet: NBI resisted disclosing an unredacted Master Summary Pricing Model/Spreadsheet, requested by the Minister under the Income Tax Act, subsection 231.7(1).

2. Privileged Legal Advice: NBI claimed the Spreadsheet contained privileged legal advice, opposing its full disclosure.

3. Tax Audit Relevance: NBI argued that the disclosure order was inappropriate as it related to a completed tax audit, forcing them into a self-audit.

Court's Findings:

• Privilege Claim: The Court found NBI's evidence on privilege insufficient, maintaining that they didn't prove the disclosure would reveal privileged advice.

• Audit Status: The Court determined the audit was not completed at the time of the decision, dismissing NBI's argument about the inappropriateness of the post-reassessment disclosure.

Conclusion:

• The Federal Court of Appeal dismissed NBI's appeal, upholding the Federal Court's decision. The Court found no error in the Federal Court's judgment regarding NBI's privilege claim, the audit's status, and the nature of the disclosure request. NBI was ordered to bear the costs.