Principal Issues: What is the process that CRA follows to designate new transactions as a notifiable transaction?
Position: The Minister of National Revenue sends a letter to the Minister of Finance to designate proposed notifiable transactions. If the Minister of Finance agrees, she will write back to the Minister of Revenue to state her concurrence to the designation of the notifiable transaction.
Reasons: Under subsection 237.4(3), the Minister may designate for the purposes of this section, with the concurrence of the Minister of Finance, in such manner as the Minister considers appropriate, transactions or series of transactions.