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…

Guest post on the DTC

The following article on the disability tax credit was written by Tanya O’Connell, a former law clerk at Loukidelis Professional Corporation. The Disability Tax Credit (DTC) The DTC is a personal tax credit available under section 118.3 of the Income…

Inter-company loans

Subsection 15(1) of the Income Tax Act could apply where Aco loans money to Bco and Bco has no means of repaying the money. On the other hand, subsection 246(1) will not apply where Bco and its shareholder have no…

Change in use and flipping

The CRA has confirmed that a deemed disposition under subsection 45(1) of the Income Tax Act resulting from a change in use is not a disposition for the purposes of the flipping rules in subsections 12(12) and 12(13). See 2024-1027831C6.

Swiss bank account trouble

In Azmayesh-Fard v R, 2025 TCC 20, the Court considered whether the CRA had properly reassessed a taxpayer beyond the normal reassessment period and imposed gross negligence penalties for unreported income from a Swiss bank account and for failing to…

Price adjustment clause

An accounting colleague has reported to me on a CRA audit involving a price adjustment clause. The CRA challenged the valuation used for a transfer of property. The taxpayer and the CRA eventually agreed on a valuation that was about…

Category: Reportable and notifiable