Dissolve – and turf everything two years later?

S. 230(4) provides that important corporate records (minute books, G.L. and key agreements) must be retained until two years following dissolution, whereas the less important stuff can be turfed (prudence aside) after 6 years.  CRA considers that, under the somewhat odd-looking rule in Reg. 5800(1)(b), once the corporation is dissolved all the records on hand must be retained for a further flat two years.

This interpretation is reminiscent of a conversation with a retired senior CRA official, who indicated that CRA’s policy was for audits (presumably outside the context of a voluntary disclosure) to not go back more than 6 years even where misrepresentation was suspected.

Neal Armstrong.  Summary of 14 June 2013 T.I. 2012-0461301E5 F under Reg. 5800(1).