Earlier this year, Canada’s mandatory reporting rules were broadly expanded by lowering the thresholds to trigger a reporting obligation and increasing the information that must be reported to the Canada Revenue Agency As a result, taxpayers may be required to flag certain mergers and acquisitions transactions in real time if it could be reasonably concluded that one of the main purposes of entering into the transaction was to obtain a tax benefit.

In this In Focus video, our Canadian Tax and Corporate Transactions lawyers discuss how common contractual protection clauses could trigger an early reporting requirement and expose taxpayers to significant penalties if they fail to report.

On 28 March 2023, Canada’s Minister of Finance tabled budget materials that propose significant changes to Canada’s General Anti-Avoidance Rule. These changes will create substantial uncertainty, increase companies’ tax risk, and add turbulence to the Canadian tax disputes landscape.