Under Section 237.4 of the Income Tax Act, the Minister of National Revenue has the authority to designate, with the concurrence of the Minister of Finance, transactions and series of transactions as requiring disclosure by taxpayers, advisers, promoters, and certain other persons. The transactions and series of transactions set out in these documents are designated for the purposes of that section. Where a transaction, or a series of transactions, is the same as or substantially similar to a transaction, or a series of transactions, so designated by the Minister of National Revenue, the trans…