Jan. 30, 2020 - In our annual Tax Review and Outlook report, we look back at significant developments that shaped the Canadian and U.S. tax landscapes in 2019 and offer our predictions on what to expect in the year ahead. Key Canadian Developments in 2019 Proposed changes to the employee stock option rules...
Extended Deadline for Québec Nominee Agreement Disclosure
As outlined in our e-communications of May 21, 2019, and August 12, 2019, Québec’s Ministry of Finance has introduced new rules regarding the disclosure of nominee agreements. The new disclosure requirement is relevant to nominee agreements involving one or more parties that are subject to Québec tax laws. As set out in the Ministry of Finance’s Information Bulletin published on May 17, 2019, nominee agreements were to be disclosed within the following timelines:
- nominee agreements entered into on or after May 17, 2019, were to be disclosed within 90 days of the date on which the nominee agreement was entered into; and
- nominee agreements entered into prior to May 17, 2019, were to be disclosed no later than September 16, 2019, to the extent that the “tax consequences” of the agreement continue after May 17, 2019.
A press release published by Revenu Québec earlier today extends the filing deadline to the later of the following dates:
- the 90th day following the date on which the nominee agreement was entered into; and
- the 90th day following the date on which the bill introducing the new disclosure requirement receives assent.
No bill has yet been introduced, and so it may be several months (or even longer) before any legislation is enacted.
This is a welcome announcement, as it will allow taxpayers to better understand the scope of the proposed rules and to meet their tax filing obligations based on actual law rather than a brief and vaguely worded information bulletin. In addition, a prescribed form will likely have been released by the time the bill is enacted, which should simplify the disclosure process.
Jan. 30, 2020 - Review of U.S. Tax Developments in 2019 In 2019, the U.S. tax world continued to be primarily concerned with developing guidance under the monumental Tax Cuts and Jobs Act (TCJA), which was enacted at the end of 2017. Major regulatory projects were proposed beginning in 2018,...