In John Doe v. Ontario (Finance), 2014 SCC 36, a tax lawyer sought disclosure of certain “policy options” prepared by the Ontario government before it enacted partially retroactive tax legislation.  The Ontario Ministry denied the lawyer’s request pursuant to an exemption in the applicable legislation for “…a record where the disclosure would reveal advice or recommendations of a public servant”.  The Supreme Court of Canada (SCC) held that the exemption applied such that the policy options were protected from disclosure.  “Advice” has a broader meaning than “recommendations”; otherwise the word “advice” would be redundant (paragraph 24).  Furthermore, the Legislature’s intention in protecting such advice – combustible material in the hands of journalists or political opponents – was to preserve an effective and neutral public service capable of producing full, free and frank advice to the elected officials (paragraph 43).