Tax alert

New mandatory disclosure rules

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Taxpayers, advisors, and promoters (and certain other parties) are required to disclose relevant information on certain tax planning or transactions to the CRA, under the new mandatory disclosure rules. Overall, the compliance burden for taxpayers, advisors, and promoters has significantly increased. These rules received Royal Assent on June 22, 2023.  

Taxpayers and their advisors should determine whether they’ll have new reporting requirements under the new mandatory disclosure rules introduced as part of Bill C-47, which came into effect on June 22, 2023. The rules contain the following changes: 

  1. An expansion of the reportable transaction rules in the Income Tax Act (the Act), along with a significantly reduced reporting deadline; 
  2. A new requirement to report notifiable transactions (five transactions specified on November 1, 2023)
  3. A new requirement for certain corporations to report uncertain tax treatments; 
  4. An extension of the normal reassessment period in non-compliance situations; and  
  5. New related penalties (some of which accrue daily or weekly) 


The information contained herein is general in nature. It is not, and should not be construed as, accounting, legal or tax advice or an opinion provided by Grant Thornton LLP to the reader. This material may not be applicable to, or suitable for, specific circumstances or needs and may require consideration of other factors not described herein. 


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