30 December 2024 Internal T.I. 2024-1031721I7 F - Notion de déclarant et statut d’Indien -- summary under Subsection 231.4(1)

CRA found that an “Indian” whose income earned during a taxation year is exempt pursuant to the Indian Act would be a “reporting entity” within the meaning of ss. 233.3 and 233.4 of the ITA, and thus be subject to the obligation to file T1135 and T1134 forms, and to penalties for failures to do so. The phrase “whose total taxable income for the year is exempt from the tax under Part I” refers to persons whose income is (absolutely) exempt pursuant to s. 149(1) and does not encompass a person (such as a status Indian) whose income from a particular source (here, income earned on a reserve) is excluded from the individual’s income.