Sure.
This bill does include changes to create new rules that would require taxpayers, and their advisers and promoters, in certain situations, to report certain aggressive tax planning to the CRA.
There are existing rules that exist in the Income Tax Act to address reportable transactions. Those are transactions that are identified through generic hallmarks related to fees that are tied to a tax benefit, contractual protection to guarantee a tax benefit, and confidential protection to protect an adviser or promoter from having the details of their plan divulged. Those rules are being amended to make them apply more broadly.
As well, there is a second set of transactions called “notifiable transactions”, which are specific types of tax planning, and those types of transactions would need to be reported to the CRA.
Then finally there are also changes related to uncertain tax treatments that are reported on a company's financial statement if they're required. Generally it's large public companies if they're required to maintain their statements in accordance with accounting principles. Then, if they report an uncertain tax treatment it would need to be reported to the CRA.
Those rules would allow the CRA to better identify aggressive tax planning, including potential situations that are subject to GAAR. The GAAR proposals that were announced in the budget—which are not in this bill but which we're consulting on—do contemplate that in order to avoid the penalty under the GAAR rules, reporting could be done to the CRA of the fact that this transaction has occurred. That reporting is proposed to occur under these mandatory reporting rules that I just discussed, so in that way the measures are linked.