Proposed transaction: request an advance income tax ruling from the CRA
Describe all parties and steps, state the requested rulings, attach the analysis and accept fees before carrying out the transaction.
An advance ruling concerns proposed transactions and complete facts. A completed transaction, hypothetical question or omitted fact may prevent a binding response.
Define the transaction
List parties, relationships, steps, amounts, expected dates, agreements and genuine commercial purpose. Separate completed steps from proposed ones.
State the rulings
Cite the precise provisions and tax conclusions requested, related questions and any existing CRA request or audit.
Prepare the package
Attach documents, organization charts, draft agreements, material facts, legal analysis and authorizations. Identify confidential information.
File before acting
Accept the fee regime, answer requests promptly and do not implement before assessing the effect of delay, withdrawal or an adverse ruling.
Advance income tax rulings — CRA