Bill 42, An Act to give effect to fiscal measures announced
in the Budget Speech delivered on 21 March 2019 and to various
other measures was assented to on September 24, 2020, bringing
into force the new rules respecting the disclosure of nominee
contracts to Revenu Québec (RQ ). The purpose of the
new rules, which were announced in Information Bulletin 2019-5 (May
17, 2019), is to “protect the integrity and fairness of the
Québec tax system.”
The Disclosure Obligation
Under the new rules, a taxpayer who is a party to a nominee
contract entered into in the course of a transaction having tax
consequences under the Québec's Taxation Act
(or who is a member of a partnership that is a party to such a
contract) must disclose the contract and the transaction to RQ.