Section 237.5

Subsection 237.5(1)

Relevant Financial Statements

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...

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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

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...

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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...

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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...

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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...

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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...

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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...

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