Reportable and notifiable

Mandatory disclosure rules (MDR) – CRA guidance

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…

Related siblings under section 55

At the 2025 APFF conference, the CRA stated that the sisters in the following scenario would be related as per subparagraph 55(5)(e)(i): Sister A and Sister B each owned 100 percent of the shares of their respective holding corporations, whose…

Subsection 55(2) can be good actually

If subsection 55(2) applies to a dividend, and the cash related to the dividend needs to be paid to an individual shareholder anyway, the shareholder will likely be better off compared to the situation obtained when the subsection does not…

Loans by a partnership to a partner

The CRA has generally held that a loan from a partnership to a partner will reduce the ACB of the partner’s partnership interest because of the “all-encompassing” language in subparagraph 53(2)(c)(v) of the Income Tax Act (Canada). The CRA has…

Directors of a dissolved corporation

In 2008, I wrote an article for the Hamilton Law Association Journal that, among other things, addressed the status of directors of a corporation that has been dissolved. I referred to Leger v R, 2007 TCC 322, which held that,…

DAC Investment

The authors discuss R v DAC Investment Holdings Inc., 2026 FCA 35, rev’g 2024 TCC 63. They conclude that, in a GAAR analysis, an overly-broad characterization of a provision or a mere description of its effect will not correctly express its object, spirit and purpose…

Category: Reportable and notifiable