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. Shannon 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. She marked practice questions for the 2004 Uniform Evaluation. In 2017, her name was added to the coveted Bunnock trophy when her team took 1st place in KWB’s 10th Annual Bunnock Tournament.

Shannon works part-time, is married and has 3 children. Away from work, she enjoys camping trips with her family, reading, attending her children’s basketball, hockey and lacrosse games. She has also been the volunteer Treasurer on the Parent Council of her children’s elementary school for the last number of years.

Shannon's Contact Information

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