Mandatory disclosure rules – Guidance, 26 April 2026 CRA Webpage

Reportable Transactions

Contingent fee arrangements

A fee does not come within (a) of reportable transaction where:

• It is a standard fee (that...

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Reportable Transactions

Confidential protection

• “Protection of trade secrets that do not relate to tax does not give rise to a reporting...

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Reportable Transactions

Contractual protection

• “Standard representations, warranties and guarantees between a vendor and purchaser, as well as...

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Notifiable Transactions

Reasonable expectation to know – no reporting

• Only advisors who know or are reasonably expected to know of their...

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Notifiable Transactions

Due diligence - notifiable transactions – no reporting

• “A person who obtained the tax benefit would generally meet...

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Reportable uncertain tax treatments (RUTTs)

RUTT restricted to matters reported on Canadian returns

• "An uncertain tax treatment is a tax...

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Footnote 2 (re "straddle transactions")

If a person enters into a series of transactions that straddle the effective date of designation, the...

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Separate reporting by equity-accounting shareholders

If the reporting corporation has uncertain tax positions that are reported on relevant...

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Exception re NT-2023-02 (re 21-year rule)

In a tiered structure, where Opco has two shareholders (100 Class “A” Common Shares owned by Trust...

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Optional filing re transactions which CRA has indicated could be subject to GAAR

• Reporting persons may file an optional disclosure regarding...

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Advisor not an advisor if no involvement with scheme

• The professional would not be considered an advisor for s. 237.4 purposes if the...

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