Mr. Shinh, the new controller of Secret Ltd., a CCPC, is in the process of preparing the company’s current-year T2 return. He notices a section of the return asking for information about the percentage ownership of the top three shareholders of the company. Secret Ltd. is so secretive that even Mr. Shinh does not know exactly how many shares the president and vice-president own. He, therefore, sends the return to Mr. Clements, the president. Mr. Clements writes “None of your business” in that section of the return, signs it, and returns it to Mr. Shinh for filing.

Mr. Shinh, worried, calls you. Secret Ltd.’s tax adviser, and asks you to speak to Mr. Clements. Mr. Shinh says that all tax owing for the year has been paid and that the return will be filed on time.

REQUIRED

What would you tell Mr. Clements about the risks, if any. Secret Ltd. is running by not completing the section of the T2 return?