Plain meaning
A written CRA statement on how it will apply specific income-tax provisions to a proposed transaction or series of transactions.
Also called
advance tax ruling
income tax ruling
Key points
- A ruling generally applies to proposed, not completed, transactions.
- The taxpayer must provide detailed facts, proposed steps, legal analysis, and fees where required.
- A ruling is binding on the CRA only for the taxpayer and transaction described, subject to stated conditions.
- Rulings are often published later in severed form without identifying taxpayer information.
Why it comes up
Advance rulings can provide certainty for major transactions, reorganizations, financing, and tax-sensitive planning.