CRA indicates that a multi-year reportable uncertain tax treatment (RUTT) must be reported in each year and that it is “reflected” in the financials if it impacts them

In addressing various questions respecting the reporting of a reportable uncertain tax treatment (RUTT) under the s. 237.5 rules, CRA indicated that:

• Where the RUTT impacts multiple taxation years, it must be disclosed in the RC3133 form for each such year.
• Uncertainty in respect of tax treatment is considered to be “reflected” in the taxpayer's relevant financial statements (the core test in the RUTT definition) where such tax treatment “impacts” those financial statements, for example, where the entity concludes that it is probable that the tax authority will not accept an uncertain tax treatment and thus it is probable that the entity will pay amounts relating to the uncertain tax treatment. The financial statements include the notes.
• Regarding the requirement in the RC3133 to disclose whether each RUT is “temporary” (presumably meaning that it will reverse within some time frame), or “non-temporary,” this determination should be made according to the accounting principles used in the relevant financial statements of the reporting corporation.

Neal Armstrong. Summaries of 20 March 2025 External T.I. 2024-1042821E5 under s. 237.5(1) - RUTT, and s. 237.5(2).