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In 2015, changes were made to the Income Tax Act to impose extensive financial disclosure obligations on labour organizations and labour trusts; information that would be made publicly available through publication on Canada Revenue Agency’s website. The broad array of information to be reported includes the salaries and benefits paid to particular officers, directors, trustees, employees and contractors.

However, the reporting requirements for labour organizations and labour trusts arising from Bill C-377 were waived by the Minister of National Revenue, effective December 21, 2015, for fiscal periods starting on December 31, 2015 and through 2016. On December 19, 2016, the Minister of National Revenue announced that these reporting requirements are waived for fiscal periods starting in 2017.

The waiver of these reporting requirements is an important step in the federal government’s commitment to repeal Bill C-377. While Bill C-377 received Royal Assent effective June 30, 2015 and is now section 149.01 in the Income Tax Act, this section has never been operative. Bill C-4 was tabled by the government on January 28, 2016 and is currently at second reading in the Senate. This bill proposes to, among other things, repeal section 149.01 of the Income Tax Act.

If you have more questions about this process, please contact Kimberley Cunnington-Taylor, a member of our Business Law Group.

This content is not intended to provide legal advice or opinion as neither can be given without reference to specific events and situations. © 2021 Nelligan O’Brien Payne LLP.

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