Quebec Nominee Disclosure: December 23, 2020 Deadline Approaching

As per our original article of June 26, 2019 ( here), concerning the obligation to disclose certain nominee contracts to Revenu Québec ("RQ"), the Quebec National Assembly has adopted the Act giving effect to the tax measures announced on the occasion the budget speech of March 21, 2019 and certain other measures (the "Disclosure Law"), which came into force on September 24, 2020.

Several elements presented by the Quebec Minister of Finance in Information Bulletin 2019-5 have been confirmed or clarified by the new Disclosure Law. The most important points are:

• only nominee contracts entered into as part of a transaction giving rise to "tax consequences" under the Taxation Act after May 16, 2019, are subject to the disclosure obligation;