Generally, a corporation must meet this new disclosure requirement where it has a minimum amount of assets at the end of the year, and it has audited financial statements, or is part of a group that has audited financial statements, that are prepared under IFRS Accounting Standards (or another country-specific GAAP relevant for public companies). Under this new requirement, which applies to taxation years that begin on or after January 1, 2023, affected corporations with a December 31, 2023 taxation year-end must file the disclosure on or before June 30, 2024. Note that Quebec has also enacted similar measures.

Affected corporations should take action now to gather all the information needed to meet this new obligation. It’s important to note that the CRA has confirmed that affected corporations will only have to disclose uncertain tax treatments that relate to an amount under the Income Tax Act including, among other items, withholding taxes and investment tax credits. Corporations that do not meet these new obligations may face consequences including extended assessment and reassessment periods and significant penalties.

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