What Are Reportable Transactions
On June 22, 2023, the new changes to the reportable transaction
regime became law when the legislation received Royal Assent. We previously raised concerns over the broadness
of the language in the draft legislation. The Canada Revenue Agency
("CRA") has now released guidance to
clarify the reporting rules. While this guidance is welcome and
assuages some of our concerns, there still remains a lot of
uncertainty that we hope will eventually be clarified through
further CRA publications, CRA assessments, or by a Court.
This article summarizes the new rules for reportable
transactions and lists our key takeaways.
Transactions that occur after June 22, 2023, will be reportable
if they meet the following criteria: