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In brief

Earlier this year, Canada’s mandatory reporting rules were broadly expanded by lowering the thresholds to trigger a reporting obligation and increasing the information that must be reported to the Canada Revenue Agency. As a result, taxpayers may be required to flag certain mergers and acquisitions transactions in real time if it could be reasonably concluded that one of the main purposes of entering into the transaction was to obtain a tax benefit.

In this In Focus video, our Canadian Tax and Corporate Transactions lawyers discuss how common contractual protection clauses could trigger an early reporting requirement and expose taxpayers to significant penalties if they fail to report

Speakers: Andrew BoydAndrew Morreale, and Haran Viswanathan.


In Focus is Baker McKenzie’s video chat series for Canadian clients. In each on-demand episode, our lawyers provide insights and quick, practical tips on today’s most pressing issues and legal developments impacting organizations operating in Canada. Explore our program to view past videos.


Author

Andrew Boyd is a partner in Baker McKenzie's Tax Practice Group in Toronto. His practice focuses on tax litigation and dispute resolution. Andrew is also an active member of the tax community, having served on the Steering Committee of the Canadian Tax Foundation’s Young Practitioner’s Group (Toronto) for four years, during which time he organized and moderated presentations on topics such as rectification, developments in GAAR jurisprudence, responding to audits, the changing tax litigation landscape, et cetera. He has also presented on evidentiary issues that arise in Tax Court trials and best practices for working with expert witnesses.

Author

Andrew Morreale is a partner in Baker McKenzie's Tax Practice Group in Toronto. Prior to joining the Firm, Andrew clerked for the judges of the Tax Court of Canada, was a corporate tax instructor at the University of Windsor, Faculty of Law and practiced in the international tax services group at a major accounting firm.

Author

Haran Viswanathan is a partner in the Corporate Transactions Practice Group in Baker McKenzie’s Toronto office. Haran is a member of the Student Recruitment Committee for the Toronto office and an active participant in the Firm’s Pro Bono initiative.