On November 2, 2021, the Government of British Columbia ("B.C.") announced it will be extending the deadline for pre-existing owners to file a transparency report with the Land Owner Transparency Registry ("LOTR") until November 30, 2022. The Ministry of Finance's information bulletin is available here.
The announcement followed extensive public consultation from various legal professionals and real estate industry associations, including a formal request for relief from the Canadian Bar Association.
All "reporting bodies" owning an interest in land will need to disclose specified "interest holders", including shareholders in a corporation, beneficiaries of a trust, and partners in a partnership, as more particularly set out in B.C.'s Land Owner Transparency Act and the Land Owner Transparency Regulation.
A LOTR transparency report requires a reporting body to not only identify these individuals, but also to disclose sensitive information about each of those individuals, including their full name, city and country of principal residence and social insurance numbers. For more complex organizations with multiple interest holders and intermediary entities, this reporting process can take significant time and expense.
Failure to file a LOTR transparency report by November 30, 2022, can have fines of up to $25,000 for an individual, or $50,000 for a corporation, or 5% of the assessed value of the property.
If you require assistance with a LOTR transparency report or general compliance under the Land Owner Transparency Act, please reach out to your contact at Miller Thomson LLP or any member of the Miller Thomson Vancouver Real Estate Group.
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