On November 26th, 2013, the Canada Revenue Agency (“CRA”) participated in a Roundtable session at the 65th Annual Tax Conference of the Canadian Tax Foundation held in Toronto, Ontario. The panelists announced a one-year pilot project for Pre-Ruling Consultations.
Taxpayers may now approach the Income Tax Rulings Directorate (“ITRD”) on a formal, written basis to obtain a preliminary ‘pre-ruling’ on a particular issue in order to determine whether the ITRD will issue a full ruling on the same issue in the future. A fee will be charged for taxpayers who use this service.
As noted on the CRA website “the purpose of the pre-ruling consultation is to reduce the likelihood of the taxpayer incurring significant costs as a result of submitting a request for a ruling that ITRD will be unable to provide.”