CPA Canada, "Uncertain Tax Treatments (“UTT Proposals”)", 5 April 2022 CPA Canada Submission

Summary Under
Tax Topics - Income Tax Act - Section 237.5 - Subsection 237.5(1) - Reportable Uncertain Tax Treatment

Should be restricted to Canadian income taxes (pp. 4-5)

  • “Reportable uncertain tax treatment” should be adjusted to clarify that the...

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Summary Under
Tax Topics - Income Tax Act - Section 237.5 - Subsection 237.5(1) - Reporting Corporation

FX conversion methodology (p. 7)

  • Given that the definition of “reporting corporation” is based on whether the corporation has assets with a...

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Summary Under
Tax Topics - Income Tax Act - Section 237.5 - Subsection 237.5(2)

Continued reporting of same issue (p. 8)

  • Reporting should be required only in years where the computation of the corporation’s taxable income...

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Summary Under
Tax Topics - Income Tax Act - Section 237.5 - Subsection 237.5(8)

S. 237.5(8) should apply only to factual information (p. 9)

  • S. 237.5(8) references “any information” relating to any transaction etc. to...

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