On June 30, 2015, a law requiring unions to publicly disclose a
wide range of their financial dealings passed the Senate and
received royal assent. Bill C-377 amends the Income Tax
Act, and requires unions to file an annual "information
return" with the Minister of Finance, containing a broad range
of previously private financial information, which notably
Financial Statements, containing a
balance sheet and income statement;
Statements showing the aggregate
amount of all transactions for the financial period, including a
separate line item for any payee who received an aggregate amount
of $5,000 or more over the period. The statements must also
provide a description of the reasons for every transaction
exceeding $5,000; and,
A statement setting out each salary
paid by the union in excess of $100,000 per year, as well as the
aggregate amount of all other salaries paid by the union.
Unions must disclose the amount of time each individually
reported salary recipient spends lobbying or performing non-labour
relations activities, as well as the aggregate time spent on those
activities by individuals whose salary is less than $100,000 per
The complete list of financial information that must be
disclosed is a long and comprehensive one. The bill requires the
Minister to publish each union's information return online. As
a result, the public will have access to the required union
financial statements. The disclosure requirements apply to unions
of all sizes across the country, including both private and public
sector unions. Unions that fail to comply with the reporting
requirements face fines of up to $25,000.
Bill C-377 is a major change to the financial reporting regime
applicable to unions. Prior to Bill C-377 unions were subject to
minimal reporting requirements.
Bill C-377 will apply to fiscal periods that begin January 1,
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