Advance Income Tax Rulings

Written by Shannon Warawa, CPA, CA on Jan. 16, 2018

Advance Income Tax Rulings are written statements providing assurance on the income tax treatment of a specific proposed transaction or transactions that you might be contemplating.

Subject to any disclaimer or qualification stated in the ruling, the ruling is considered binding with respect to the specific taxpayer making the request and the specific proposed transaction.

Some other key facts include:

the ruling is considered binding

  • Advance income tax rulings are generally requested by tax professionals on behalf of their clients;
  • Advance income tax rulings are only issued in response to written requests that include all required information;
  • The charge for a ruling is $100/hour for the first 10 hours spent and $155/hour thereafter;
  • Advance rulings are generally issued within 90 days of the Income Tax Ruling Department receiving all required information;
  • The Department is not obligated to issue an advance ruling when requested.  For example, the Department will not issue a ruling if the specific transaction is not seriously being contemplated or the time frame for completion is not definite.

Rulings are generally issued within 90 days

Before requesting an advance ruling, a taxpayer may also consider a pre-ruling consultation which allows the taxpayer or their representative to discuss a particular issue critical to the structuring of the proposed transaction.  Pre-ruling consultations are subject to the same fees.

You may also consider a pre-ruling consultation

Requests can be mailed, faxed or emailed to the Advance Income Tax Rulings Department at:

Canada Revenue Agency

11th floor, Tower B

Place de Ville, 112 Kent Street

Ottawa ON K1A 0L5

Fax: (6130 957-2088

Email: itrulingsdirectorate@cra-arc.gc.ca

If you would like more information or have any questions, feel free to contact us at 780.466.6204, or click here to send us an email.

Thanks to Shannon Warawa of KWB Chartered Professional Accountants for providing this content.

Shannon Warawa, CPA, CA

Shannon Warawa, CPA, CA

Manager

Shannon Warawa joined KWB in September 2005. She received her Bachelor of Commerce from the University of Alberta in 1999. After articling with PricewaterhouseCoopers for three years, she was employed with Howard Kirkpatrick Associates during which time she obtained her C.A. designation. Shannon is the first point of contact for the majority of clients handling the affairs of a deceased parent or spouse and would be happy to answer any questions and assist in the preparation of their final personal tax return.

In 2017, her name was added to the coveted Bunnock trophy when her team took 1st place in KWB’s 10th Annual Bunnock Tournament. In 2018, she defended her title with her office partner Haley.

Shannon works part-time, is married and has 3 children. Away from work, she enjoys camping trips with her family, reading, cheering at basketball, hockey and lacrosse games, book club and her weekly boot camp classes. She served as Parent Council Treasurer for many years at her children’s elementary school and continues to volunteer in her children’s schools whenever possible.

Shannon's Contact Information

Other Posts by Shannon

Jan 14 2020
5 Things to Consider When Filing Your Tax Return

Here’s a list of some things to avoid when filing your tax return. Follow these tips; they could save you time and money! Filing an income tax and benefit return even if you have no income If you have no income to report, you should still file a return. You may be eligible for

Mar 21 2017
CRA Fraud Protection

Canada Revenue Agency and police again warned taxpayers of randomly targeted fraudulent telephone calls and e-mails that are being sent out as CRA fraud.  These phone calls and e-mails are not from the CRA. Annually the number of CRA fraud scams rise near the April 30th tax deadline. The phone call scams are imposters trying

May 4 2020
CPP Death Benefit and Survivor Payment

CPP death benefit The CPP death benefit is a one-time, lump-sum payment to the estate of the deceased contributor. The CPP death benefit can be paid to: The Estate of the deceased person The person who paid the funeral expenses A surviving spouse or common law partner A next of kin. The Executor is the first

Mar 19 2019
Applying for a trust account number or asking for a clearance certificate

Asking for a clearance certificate A clearance certificate certifies that all amounts for which a deceased taxpayer is liable to Canada Revenue Agency for have been paid.  If a clearance certificate is not obtained upon a taxpayer’s death, as the legal representative, you can be liable for any amount the deceased owes.  A

Apr 26 2016
Estate Planning Gifting Strategy

An estate planning gifting strategy is basically when you start to give away some of your assets prior to death in order to optimize taxes within the family. Usually, an estate planning gifting strategy refers to how we will distribute our assets when we die.  But you might be overlooking significant tax savings by not

Aug 30 2016
Graduated Rate Estates – New Rules for 2016

Starting for 2016 taxation years, inter vivos trusts, trusts created by will and certain estates will be subject to the top taxation rate. There are two exceptions to this change: graduated rate estates and qualified disability trusts. Graduated tax rates will still apply to these types of estates and trusts. Income earned and retained in

Nov 15 2016
Top 4 Financial Tips for the New Parent

Here are our top 4 financial tips for the new parent: Apply for a Social Insurance Number (SIN) for your child: It’s a good idea for you to apply for a Social Insurance Number for your child as soon as they are born. This way, you will not be left scrambling to obtain one when your

Mar 28 2017
EI, OAS and CPP Rulings

Employment and Social Development Canada (“ESDC”) is responsible for EI, OAS and CPP rulings, not Canada Revenue Agency. On April 1, 2013, the Social Security Tribunal (“SST”), an independent administrative tribunal operating at arm’s length from ESDC, was introduced to review appeals on EI, OAS and CPP rulings made by the ESDC. The process to

Feb 12 2019
Direct Beneficiary Designation - RRSP or RRIF

If you are considering a direct beneficiary designation for either a Registered Retirement Savings Plan (RRSP) or a Registered Retirement Income Fund (RRIF), you should be aware of some negative consequences that can occur. A direct beneficiary designation can result in unintended tax consequences to the estate, the inequitable treatment of heirs or the distribution

Aug 7 2018
Form T1135 Foreign Income

Form T1135 Foreign Income Verification Statement must be filed if you, your corporation, trust or partnership, owned or held foreign property with a cost amount of more than $100,000 at any time in the year even if some or all of the property was sold before the year of the year. The form is

Sep 24 2019
Receipt Bank

If you would like to spend less time organizing your records and more time growing your business, you should automate your document retention with Receipt Bank. Receipt Bank is a website application that extracts key information from your invoices and receipts and publishes it directly into Quickbooks Online (QBO). Integrates with QBO Some of the