[Verse 1]
When taxpayers cross the line from smart to wrong
Criminal charges come along
Section two-three-eight makes it clear
False statements bring prosecution near
Two-three-nine hits tax evasion hard
Prison time is on the card
Planning's fine but fraud's a crime
Don't do the evasion time
[Chorus]
GAAR is watching, disclosure's here
Reportable transactions must be clear
Two-three-eight, two-three-nine, don't you hide
Deans Knight shows the courts decide
Mandatory rules, penalties steep
Aggressive planning secrets you can't keep
[Verse 2]
General Anti-Avoidance Rule
GAAR's become a sharper tool
Deans Knight changed the game in twenty-three
Supreme Court set the jurisprudence free
Object, spirit, purpose test
Abusive transactions fail the rest
Tax benefits can disappear
When substance isn't crystal clear
[Chorus]
GAAR is watching, disclosure's here
Reportable transactions must be clear
Two-three-eight, two-three-nine, don't you hide
Deans Knight shows the courts decide
Mandatory rules, penalties steep
Aggressive planning secrets you can't keep
[Bridge]
Twenty-twenty-three amendments came
Changed the disclosure game
Reportable and notifiable too
Revenue Agency's watching you
Uncertain treatments must be told
Or face penalties manifold
[Verse 3]
Promoters selling schemes beware
Disclosure rules are everywhere
Hallmarks trigger filing dates
Miss them and penalty awaits
Uncertain tax positions disclosed
Keep your books and records closed
Aggressive planning has a cost
Play it safe or all is lost
[Chorus]
GAAR is watching, disclosure's here
Reportable transactions must be clear
Two-three-eight, two-three-nine, don't you hide
Deans Knight shows the courts decide
Mandatory rules, penalties steep
Aggressive planning secrets you can't keep
[Outro]
Tax avoidance versus tax evasion
Know the line, avoid temptation
Follow rules and pay your share
Canada's tax system needs your care