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On the above issue, note in brief the following:

• recall that the ISC rules came into force in June 2019, with an internal corporate register that can be accessed by CRA/Revenu Quebec/the police in the context of certain investigations, and with potential fines of up to $200,000 for not following many of the major rules for keeping the internal register;
• in the April 7, 2022 federal budget, it was announced that the abovementioned register would be a public register by the end of 2023, but no legislation was tabled. Here is the first of such legislation:
• regarding the April 28, 2022 budget implementation bill which has passed first reading, the related news release states that the government is “taking the first steps towards the implementation of a publicly accessible beneficial ownership registry of federally incorporated corporations.” The bill contains a provision that would amend the ISC rules in the CBCA to oblige CBCA corporations (other than public companies) to provide their ISC register to Corporations Canada on an annual basis or whenever the register changes. [Those are the “first steps” referred to in the news release mentioned above.]  Corporations Canada would be able to give the register to CRA/Revenu Quebec/the police in the context of certain investigations, and would be able to give the register to FINTRAC, but otherwise this new bill does not make the registers public.  This would come into force by order in council (i.e., at a time designated by the government) after the legislation is passed.

Bottom line on the above:  possibly the federal government is skittish to set up a public register, but hopes the fear of fines for non-filing with Corporations Canada will encourage compliance.

It is not clear when the above new rule for filing with Corporations Canada will come into force, but anything past 2023 will be a pull-back from statements made by the federal government since December 2021 at the Summit for Democracy in Washington.

Further developments on beneficial ownership transparency for corporations and their shareholders (including often trusts that are shareholders) can be expected in 2022, as regulations for the above federal rules may be released and implementation dates may become clearer;  furthermore, Quebec has stated that its similar register of ultimate beneficiaries of private corporations and partnerships is currently scheduled to come into force in March 2023, and confirmation of that and potential regulations or guidance on those rules is expected from Quebec by late 2022 or so.

At this link [HERE] is my article from January 2022, that appeared in Tax Topics (published by Wolters Kluwer), which compares most of the main rules on this, as between the Federal and the Quebec legislation.

Please do not hesitate to contact me if you have any questions on this or other matters.