Subsection 237.5(1)
Relevant Financial Statements
Administrative Policy
Mandatory disclosure rules – Guidance, 15 August 2024 CRA Webpage
Separate reporting by equity-accounting shareholders
If the reporting corporation has uncertain tax positions that are reported on relevant...
Reportable Uncertain Tax Treatment
Administrative Policy
20 March 2025 External T.I. 2024-1042821E5 - Application of 237.5 - RUTT disclosure
Q.1 Multi-year RUTTs
Where the audited financial statements for a year reflect a recurring uncertain tax treatment (“UTT”) spanning multiple...
Words and Phrases
reflected| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 237.5 - Subsection 237.5(2) | whether RUTT is temporary or non-temporary is determined according to the accounting principles used | 90 |
Mandatory disclosure rules – Guidance, 15 August 2024 CRA Webpage
Reportable uncertain tax treatments (RUTTs)
RUTT restricted to matters reported on Canadian returns
- "An uncertain tax treatment is a tax...
Articles
CPA Canada, "Uncertain Tax Treatments (“UTT Proposals”)", 5 April 2022 CPA Canada Submission
Should be restricted to Canadian income taxes (pp. 4-5)
- “Reportable uncertain tax treatment” should be adjusted to clarify that the...
Reporting Corporation
Articles
CPA Canada, "Uncertain Tax Treatments (“UTT Proposals”)", 5 April 2022 CPA Canada Submission
FX conversion methodology (p. 7)
- Given that the definition of “reporting corporation” is based on whether the corporation has assets with a...
Subsection 237.5(2)
Administrative Policy
20 March 2025 External T.I. 2024-1042821E5 - Application of 237.5 - RUTT disclosure
The RC3133 form requires disclosure of whether each disclosed RUTT is “temporary” or “non-temporary.” When determining if a RUTT is...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 237.5 - Subsection 237.5(1) - Reportable Uncertain Tax Treatment | the same uncertain tax treatment (UTT) must be reported in multiple successive returns if it spans several tax years/ UTT is “reflected” in the financials if it impacts them | 395 |
Articles
Dean Landry, Colin Mowatt, "The Uncertainty Surrounding Uncertain Tax Treatments", Perspectives on Tax Law & Policy, Vol. 4, No. 3, September 2023, p. 13
Background (p. 13)
- The key definitions in s. 237.5 are modelled on IFRIC 23, which indicates that if the company identifies an uncertain position...
CPA Canada, "Uncertain Tax Treatments (“UTT Proposals”)", 5 April 2022 CPA Canada Submission
Continued reporting of same issue (p. 8)
- Reporting should be required only in years where the computation of the corporation’s taxable income...
Subsection 237.5(8)
Articles
CPA Canada, "Uncertain Tax Treatments (“UTT Proposals”)", 5 April 2022 CPA Canada Submission
S. 237.5(8) should apply only to factual information (p. 9)
- S. 237.5(8) references “any information” relating to any transaction etc. to...