New subsection 233.1(2) of the Act provides that a reporting person (see the definition in proposed new subsection 233.1(1) of the Act) must file an information return for a taxation year in respect of the reportable transactions (see the definition in proposed new subsection 233.1(1)) in which the reporting person and a non-resident non-arm’s length person (or a partnership of which that non-resident person is a member) participated in the year. The return must be filed by the reporting person’s filing-due date for the year. A separate return is required to be filed for each such non-resident person (or partnership). New subsection 233.1(2) applies to taxation years and fiscal periods that begin after 1997
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