Plain meaning
Rules requiring disclosure of certain transactions or tax positions to the CRA.
Also called
uncertain tax treatment
notifiable transaction
reportable transaction
Key points
- Mandatory disclosure rules require certain transactions or uncertain tax positions to be reported to the CRA.
- The rules include categories such as reportable transactions, notifiable transactions, and reportable uncertain tax treatments for specified corporations.
- Reporting obligations can apply to taxpayers, advisers, promoters, and other persons depending on the rule.
- Late or missing disclosure can lead to significant penalties and can affect reassessment periods.
- These rules are meant to give the CRA earlier information about aggressive or uncertain tax positions.
Why it comes up
Disclosure rules affect taxpayers, advisors, corporations, penalties, and CRA audit visibility.