Canada (National Revenue) v Atlas Tube Canada ULC is the latest in a series of cases considering the ability of the Canada Revenue Agency (CRA) to compel corporate disclosure of confidential reports analyzing the tax positions of a company. In Atlas Tube, the Federal Court held that CRA could compel taxpayers to disclose sensitive accounting reports in the context of an active audit under sections 231.1 and 231.7 of the Income Tax Act. Taxpayers engaging in transactional due diligence should carefully consider the source and content of reports acquired for planning purposes.