Quebec recently passed measures to require either party to a nominee agreement that is made as part of a transaction, or a series of transactions, to disclose this information by December 23, 2020 or 90 days after conclusion of the nominee agreement, whichever is later. This obligation applies to all nominee agreements entered into on or after May 17, 2019, as well as certain agreements entered into before this date where the tax consequences continue after May 16, 2019.

Quebec taxpayers must meet this new requirement by filing a prescribed form for qualifying nominee agreements even if they already disclose details of such an arrangement in their provincial tax return. Taxpayers who do not disclose nominee agreements they are a party to face penalties of up to $5,000.

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