Subsection 237.5(1)
Relevant Financial Statements
Administrative Policy
Mandatory disclosure rules – Guidance, 2 November 2023 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
Mandatory disclosure rules – Guidance, 2 November 2023 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)
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...