A mandatory disclosure must be filed by any adviser or promoter (or, if they are partnership, by one of their members) that commercialized or promoted a transaction where the form and substance of the facts concerning the transaction are very similar to those of the facts of a transaction determined by the Minister. The transaction must not have required a significant modification to its form and substance to adapt it for implementation with various taxpayers or partnerships.

Disclosure deadline

The disclosure must be filed by the later of the following dates:

• 60 days after the day on which the adviser or promoter first commercialized or promoted the transaction; or
• 120 days after the day on which the transaction determined by the Minister was published for the first time.

The disclosure must be made using form TP-1079.CP-V, Mandatory Disclosure of Tax Planning by an Adviser or Promoter.

Penalties may apply if you fail to meet the deadline.