Section 277

Administrative approach to avoiding duplicate reporting

10.13 Administratively, when subsections 277(4) and (5) apply, the CRA allows the following:

• The financial institution may report the account it maintains based on information provided from the dealer, and it must inform the dealer in writing that the financial institution will do the reporting. This alternative relieves the dealer from the reporting obligation; or
• The dealer may do both the due diligence and reporting obligations for the client name account, provided the dealer also advises the financial institution in writing that, in addition to communicating the status of the accounts, it (the dealer) will do the reporting. In such cases, information return filed by the dealer for such client name accounts must identify the fund as the reporting financial institution.

This approach avoids duplicate reporting (if any) in respect of the financial asset.

When only the financial institution reports the account, it must advise the dealer in writing that it will assume the reporting obligations for the account. In that case, the Part XIX information return should be filed using the Business Number of the financial institution.

When the dealer does both the due diligence and the reporting, it must advise the financial institution in writing, which accounts are reportable, and that it will be responsible for the reporting as well. In situations where no accounts are determined to be reportable, the dealer must also communicate to the financial institution that no accounts are reportable for the calendar year.