Mandatory Disclosures, Notifiable Transactions and Uncertain Tax Positions

This module delves into the Canadian regime for mandatory tax disclosures, with a focus on reportable transactions under Section 237.3, notifiable transactions under Section 237.4, and the evolving treatment of uncertain tax positions. Participants will explore the underlying policy rationale behind transparency-driven disclosure obligations and examine how these provisions interact with broader CRA enforcement strategies. The course examines key hallmarks of reportable transactions, CRA-identified notifiable schemes, and the accounting treatment of uncertain positions under IFRS and GAAP. Real-world case studies and audit simulations will be used to illustrate the consequences of non-disclosure, the responsibilities of tax advisors, and best practices for mitigating compliance risks in both corporate and advisory contexts.