Under these rules, affected businesses that earn specific kinds of online revenues that meet certain thresholds must register by January 31, 2025, and may also have to file their first DST returns and pay the DST owing by June 30, 2025. Note that, when affected businesses file their first DST return, they must include DST owing on certain online revenues earned since January 1, 2022. Affected businesses that do not meet their new registration, filing and other compliance obligations as required could face significant penalties and interest.

In addition to registering for a DST program account on the CRA portal by January 31, 2025, taxpayers who are preparing to meet their DST obligations will have to consider many compliance issues related to these complex new rules, some of which were identified after the rules were first released. In particular, these taxpayers will have to address concerns including properly determining whether certain kinds of income are considered in-scope revenues under broad categories and definitions, and whether their in-scope revenues meet registration and filing thresholds. In addition, businesses that are members of consolidated groups may be subject to specific DST rules that can affect their compliance obligations. Affected businesses may also want to consider calculating and accruing quarterly and year-end reserves related to a DST liability for financial reporting purposes.

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