Canada: List of “notifiable transactions” under new mandatory disclosure rules
Effective 1 November 2023
New mandatory disclosure rules
The Canada Revenue Agency (CRA) has issued a new list of officially designated “notifiable transactions” under the expanded new mandatory disclosure rules.
Individuals, corporations, trusts, and partnerships are obligated to identify whether they have to disclose information about certain transactions generally within 90 days of either contracting to enter into, or entering into, the transaction. The requirement to report designated notifiable transactions to the CRA is a part of several recent revisions to the mandatory disclosure rules, which also expand taxpayer reporting obligations related to “reportable transactions” and introduce new disclosure requirements for certain corporations for “uncertain tax treatments” reflected in their audited financial statements.
The CRA’s list identifies the following “notifiable transactions,” effective 1 November 2023:
- Straddle loss creation transactions using a partnership
- Transactions to avoid a deemed disposal of trust property
- Transactions that manipulate bankrupt status to reduce a forgiven amount in respect of a commercial obligation
- Transactions that avoid a deemed acquisition of control by relying on purpose tests in section 256.1
- Back-to-back arrangements
Read a November 2023 report [PDF 215 KB] prepared by the KPMG member firm in Canada
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