Bill C-377 May Inadvertently Impose Costly Reporting Requirements On Investment Funds

On June 30, 2015, Bill C-377, a private member's bill that is intended to mandate disclosure of union financial activities, received Royal Assent (S.C. 2015 c.41).  Subject to certain exceptions, this controversial bill adds a provision to the Income Tax Act (Canada) which will require "labour organizations" and "labour trusts" to provide extensive disclosure regarding their financial activities to the Canada Revenue Agency.  According to the legislation, the Canada Revenue Agency will make this disclosure available to the public, including by way of "publication on the departmental Internet site in searchable format".  These reporting requirements will apply to fiscal periods beginning after December 31, 2015.