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CRA mandatory disclosure rules guidance – Update

CPA Canada recognizes that the Canada Revenue Agency’s (CRA) initial guidance, released on July 5th, did not address all our members questions regarding administration of the rules.

CPA Canada recognizes that the Canada Revenue Agency’s (CRA) initial guidance, released on July 5th, did not address all our members questions regarding administration of the rules. The objective of CRA’s initial guidance was to ensure timely guidance was provided to taxpayers and their advisors.

Representatives from the CRA advised the Joint Committee on Taxation of the Canadian Bar Association and CPA Canada (Joint Committee) that the published guidance will evolve as the CRA continues to review the feedback received from key stakeholders, including the Joint Committee.

Common issues we received from members have already been brought to CRA’s attention in the Joint Committee’s feedback for consideration, such as:

  • explain if standard limitation of liability clauses trigger the contractual protection hallmark;
  • provide more examples of acceptable value billing situations that involve a tax benefit;
  • provide more commentary and examples related to the determination of the reporting due date under various common scenarios;
  • minimize the information reported on the RC312 to reduce the administrative burden; 
  • provide more examples of common commercial transactions and terms and conditions that would generally not fall within one of the three hallmarks.

We are thankful that the CRA continues to have discussions with the Joint Committee on the administration of the MDR. We will provide you with timely updates as new information becomes available.