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Cases will clarify focus of reporting requirements

May 13, 2009

Two cases before the Tax Court of Canada relate to financial transactions meaning taxpayers with intercompany financial transactions should be prepared for greater scrutiny under newly introduced reporting requirements.

On December 22 2008 the Canada Revenue Agency (CRA) released a new version of the information reporting form T106 that includes significantly expanded levels of detail for disclosures of related party transactions. Any taxpayer that enters into a transaction or series of transactions with an aggregate value of C$1 million ($849,577) or more in a given year is required to complete and submit form T106 by the due date for the tax return for that year, disclosing all transactions with non-arm’s length non-residents.

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