Mandatory Disclosure of Tax Planning by an Adviser or Promoter in Respect of a Transaction Determined by the Minister
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.
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.