The government declared that Federal Budget 2021 ("Budget
2021") is about finishing the fight against COVID-19 and
creating prosperity for Canadians in the decades to come.
Supporting this stated objective are new and enhanced tax
administration and enforcement measures targeted at increasing tax
revenues, including strengthening mandatory disclosure rules,
proposed new measures to combat international tax avoidance,
tackling tax evasion, aggressive tax avoidance and schemes to avoid
collections, as well as enhanced Canada Revenue Agency
("CRA") audit powers.
Mandatory disclosure rules
Budget 2021 cites a lack of timely information concerning
so-called aggressive tax planning as a major challenge for tax
administrations. The government's lack of success in its
existing legislative and litigation agendas, which were undertaken
to peel back the tax planning curtain, likely informed the
disclosure rule proposals in Budget 2021. Comments on the proposals
may be