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Jun 21, 2023 · Canada’s enhanced mandatory disclosure rules are a set of reporting requirements which received royal assent on June 22, 2023. Enhancements to the rules align with international best practices and aim to better provide the Canada Revenue Agency (CRA) with information to respond to tax risks. Who may be impacted: individuals, corporations ...
- Guidance
The mandatory disclosure rules include revisions to the...
- Guidance
The mandatory disclosure rules include revisions to the existing rules related to reportable transactions. The mandatory disclosure rules also require reporting with respect to notifiable transactions and uncertain tax treatments. Notifiable transactions differ from reportable transactions in that notifiable transactions are those that the ...
Feb 1, 2024 · Canada’s mandatory disclosure rules were significantly expanded in 2023. Three separate regimes comprise the rules: reportable transactions, notifiable transactions and reportable uncertain tax treatments (RUTT). Read below for a brief overview of each, as well as related procedural and penalty rules.
Jul 5, 2023 · Updated: January 12, 2024. 7 min read. Article. With the royal assent of Bill C-47 on June 22, 2023, changes to Canada’s income tax mandatory disclosure rules are law, and the Canada Revenue Agency (CRA) has recently issued new guidance on these new rules. The mandatory disclosure rules expand the reportable transaction rules and introduce ...
- In Brief
- In Detail
- The Takeaway
On April 20, 2023, the federal government tabled Bill C‑471, which includes the legislation to implement revised and expanded disclosure rules relating to tax avoidance transactions and uncertain tax treatments, commonly referred to as the mandatory disclosure rules (MDR). These measures were initially announced in the 2021 federal budget, with dra...
Notifiable transactions
Bill C‑47 introduces a requirement to file a prescribed information return for a new category of specific transactions (known as “notifiable transactions'') that have been designated by the Minister of National Revenue, with the concurrence of the Minister of Finance. Taxpayers, advisers and promoters will be required to report a transaction or series of transactions that is the same as, or substantially similar to, a “designated” transaction or series of transactions. Transactions will be co...
Uncertain tax treatments
Bill C‑47 also introduces a requirement to disclose “uncertain tax treatments.” The rules will require a corporate taxpayer that meets all of the following conditions to annually report particular uncertain tax treatments: 1. the corporation is required to file a Canadian income tax return, and has at least $50 million in assets at the end of the relevant taxation year 2. the corporation, or a group of which the corporation is a member, has audited financial statements prepared in accordance...
Assessment limitation period
In addition to direct financial penalties, all three MDR regimes extend the reassessment period for any transaction, including an uncertain tax treatment, until three or four years (depending on the type of taxpayer) after all applicable reporting requirements have been complied with. In the context of the reportable and notifiable transactions regimes, this would seem to imply that a non-filing by an adviser or promoter in respect of a relevant transaction could impact the taxpayer’s tax sit...
With royal assent of Bill C‑47 expected in June 2023, taxpayers, advisers and promoters should start complying with these new rules very soon. Unfortunately, many interpretive uncertainties remain unresolved, most particularly with respect to how the rules apply to transactions before the designation date of a notifiable transaction and the intende...
Jul 20, 2023 · On 22 June 2023, the new rules to enhance Canada’s mandatory disclosure requirements included in Bill C‑47, Budget Implementation Act, 2023, No. 1, became enacted. 1 The new rules, which include an expansion of the existing reportable transaction rules and new reporting requirements for notifiable transactions and reportable uncertain tax treatments, are intended to provide the Canada ...
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Apr 25, 2023 · Budget Implementation Act, 2023, No. 1, which includes the Canadian income tax mandatory disclosure rules, was introduced in Parliament on April 20, 2023 as Bill C-47. First announced in Budget 2021, the mandatory disclosure rules expand the existing reportable transaction rules and introduce new reporting obligations in respect of “notifiable transactions” and “reportable uncertain tax ...
