Canadian Mandatory Disclosure Rules Update: First List Of Designated Notifiable Transactions Released

The Canadian Minister of National Revenue published the first list of designated notifiable transactions under the mandatory disclosure rules on November 1, 2023. First announced in Budget 2021, the notifiable transaction rules introduced new reporting obligations in respect of transactions that are the same or substantially similar to those included on the list. Failure to comply with the new rules results in an extension of the normal reassessment period and can result in significant penalties.

One day after releasing the list of designated notifiable transactions, the Canada Revenue Agency (CRA) updated its guidance on the mandatory disclosure rules. The updates include important changes to the contractual protection hallmark of the reportable transaction rules. A separate Osler Update will follow setting out these changes and their implications for taxpayers' obligations under the mandatory disclosure rules.