CRA will not provide administrative relief from duplicative T1134 filing requirements resulting from amalgamations or CFA transfers

CRA will not provide any administrative relief from the duplicative T1134 reporting required as a result of the amalgamation of two Cancos in a group, each with controlled foreign affiliates (resulting in two year ends in the calendar year of the amalgamation, assuming Amalco also has a calendar year end) or as a result of transferring CFAs between group members during the year, stating that providing such relief “would diminish the transparency of the offshore structures, which frustrates one of the purposes of the form.”

Electronic filing of T1134s, and T106 returns, by mid-2017 is anticipated. Transmission of supporting financial documentation is still being worked on.

Neal Armstrong. Summary of 26 April 2017 IFA Roundtable, Q.6 under s. 233.4(4).