Mandatory disclosure rules – Guidance, 15 August 2024 CRA Webpage

Reportable Transactions

Contingent fee arrangements

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

• It is a standard fee (that...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Reportable Transactions

Confidential protection

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

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Reportable Transactions

Contractual protection

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

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Notifiable Transactions

Reasonable expectation to know – no reporting

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

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Notifiable Transactions

Due diligence - notifiable transactions – no reporting

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

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Reportable uncertain tax treatments (RUTTs)

RUTT restricted to matters reported on Canadian returns

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

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Footnote 2 (re "straddle transactions")

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

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Separate reporting by equity-accounting shareholders

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

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Application of NT-2023-05 (re B2B arrangements) to cash pooling arrangements

NT-2023-05. Back-to-back arrangements

In the context of a...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.