Mandatory Disclosure Rules

On June 22, 2023, Bill C-47 Budget Implementation Act, 2023, No. 1 received royal assent. Bill C-47 includes legislation to implement the new mandatory disclosure rules originally proposed in the 2021 federal budget. The upgraded mandatory disclosure rules will require taxpayers and advisors to disclose “reportable transactions” and “notifiable transactions” to the CRA. On July 6, 2023, the CRA published administrated guidance regarding their approach to the application of the mandatory disclosure rules. Given penalties for non-compliance are significant for both taxpayers and advisors, the CRA guidance is welcoming.

Instructor(s): Joe Figliomeni, tax partner at Fazzari + Partners LLP