Corinne Grigoriu and Neil Burnside have authored an article titled “Notifiable Back-to-Back Arrangements: CRA’s Transactions of Interest,” published by Wolters Kluwers’ International Tax in Report No.: 139.
Write Corinne and Neil:
“The notifiable transaction rules in section 238.4 of the Income Tax Act (Canada) were introduced in federal budget 2021. Those rules require the reporting of certain transactions identified by the Minister of National Revenue as being avoidance transactions or transactions of interest. The notifiable transaction rules, together with expanded reportable transaction rules and reporting requirements for uncertain tax positions were introduced in response to a perceived lack of timely, comprehensive, and relevant information on aggressive tax planning strategies.”
The full article is available for subscribers of CCH AnswerConnect.