Mar 30th, 2022
May 3rd, 2022
By Daniel Frajman
On the above issue, note in brief the following:
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.