!["What the revenue authorities are seeking is a guided tour
through any potential problems in the taxpayer's
tax filings, from the taxpayer's specific
subjective view," said John Sorenson of Gowlings, Taxand
Canada.
"The concern [for businesses] is disclosure of specific
analyses that underlie the reserves," said Sorenson. "A reserve
might be opaque, but what the revenue authorities want is
detailed information as to why the reserve was claimed."
In Minister of National Revenue v BP Canada Energy
Company, the FCC demanded that BP hand over tax accrual
working papers, which had previously been requested by the CRA
in its audit of the company.
BP argued that the papers fell...
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Canadian public companies must disclose contingent tax liabilities after Federal Court's BP ruling
- 1. Canadian public companies must disclose contingent tax liabilities after Federal Court's BP ruling 09 July 2015 Joe Stanley-Smith After a Federal Court of Canada (FCC) ruling, publicly-listed companies could have to disclose technical analyses of their contingent reserves for potential tax liabilities, leading to fears the information could be used by the Canada Revenue Agency (CRA) to challenge businesses' tax returns. The amounts of money held in contingency for potential losses is already disclosed in companies' financial statements under Canadian company law, but exposing the rationale behind planning for losses in tax cases could make the CRA's job easier.
- 2. "What the revenue authorities are seeking is a guided tour through any potential problems in the taxpayer's tax filings, from the taxpayer's specific subjective view," said John Sorenson of Gowlings, Taxand Canada. "The concern [for businesses] is disclosure of specific analyses that underlie the reserves," said Sorenson. "A reserve might be opaque, but what the revenue authorities want is detailed information as to why the reserve was claimed." In Minister of National Revenue v BP Canada Energy Company, the FCC demanded that BP hand over tax accrual working papers, which had previously been requested by the CRA in its audit of the company. BP argued that the papers fell... This article is locked content, available to current subscribers or trialists. Current subscribers or trialists - Please log in to view this article in full.
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