The authors provide notes on the CRA’s updated guidance on the MDR. Taxpayers must report a series of transactions that includes a notifiable transaction if the series straddles the date the transaction is designated as such. The CRA list of…
Notifiable transactions list
The CRA has posted the list of notifiable transactions that have been designated by the Minister of National Revenue effective today. In the email I received notifying me of the notifiable transactions list, the CRA wrote “The list of transactions…
Reportable Transactions and Adviser Fees
Last year, the Department of Finance proposed amendments to section 237.3 of the Income Tax Act (Canada) (the “Act”) that reduced to one the number of “hallmarks” that would trigger reporting on an avoidance transaction. In response, the Joint Committee…
Reportable and notifiable transactions
Amit Ummat and I published the following article in the most recent edition of the Hamilton Law Association Journal. One important point: Finance has postponed the coming into effect of the new rules to 2023. Lawyers can usually assist with…