CRA indicates that generally only the GL rather than ancillary journals or back-up are subject to the extended corporate accounting-record retention period

The various records or books of account of a corporation described in Reg. 5800(1)(a) are to be kept until two years after its dissolution, whereas other records or books of the corporation need only by kept until six years after the taxation year to which they relate.

Regarding the scope of Reg. 5800(1)(a)(iv), which refers to “the general ledger or other book of final entry containing the summaries of the year-to-year transactions of a corporation,” CRA indicated that:

• In general, the term “summary” refers only to the summary items posted to the general ledger (GL), so that more details, such as the names of the parties and the dates of the transactions, are not required.
• However, in some cases, the GL may present only a total for several transactions otherwise presented individually in another book of final entry, such as a subsidiary ledger, in which case such subsidiary ledger is also subject to the longer retention period.
• Notwithstanding some ambiguity in this regard arising under the wording of ITA s. 230(4)(a). the vouchers and accounts required to verify the information contained in the GL are only subject to the shorter (six-year) retention period.

Reg. 5800(1)(a)(v) refers to “any special contracts or agreements necessary to an understanding of the entries in the [GL]”. CRA stated:

Generally speaking, we are of the view that a special contract or agreement is one that includes particular provisions or conditions that are not generally found in a contract or agreement of a similar nature.

Neal Armstrong. Summaries of 5 July 2023 External T.I. 2022-0954271E5 F under Reg. 5800(1)(a)(iv) and Reg. 5800(1)(a)(v).