CRA indicates that the possibility of engaging in a notifiable transaction does not establish a filing requirement

On the settlement of a family trust, the beneficiaries include Canadian corporations owned by an individual beneficiary, who may attend a US university and become a non-resident at some point.

CRA indicated that, as no person had yet entered into, or become contractually obligated to enter into, a transaction or a series of transactions that were the same as or substantially similar to the designated transactions in NT2023-02, the above possibility was not sufficient to establish that a notifiable transaction had been entered into, nor did it create any contractual obligation to enter into one – so that no notification through an RC312 filing was yet required.

Neal Armstrong. Summary of 2 June 2026 STEP Roundtable, Q.10 under s. 237.4(4).