SUBJECT: Advance rulings (income Tax and GST/HST)
Principal Issues: Information on advance rulings
Position: General information provided
March 6, 2017
XXXXXXXXXX
Dear XXXXXXXXXX:
Thank you for your correspondence asking for information on advance tax rulings. Thank you also for your understanding regarding the delay of this response.
The Income Tax Rulings Directorate (ITRD) of the Canada Revenue Agency (CRA) offers advance income tax rulings and technical interpretations on specific provisions of the Income Tax Act. Generally, where CRA has a tax collection agreement (TCA) with another province, the ITRD can issue advance income tax rulings or technical interpretations for that province. The TCAs are in place for the administration of personal income tax for all provinces except Quebec. For corporate income tax administration, TCAs exist for all provinces except Quebec and Alberta. I encourage you to write to these two provinces to see if they offer rulings on personal income tax and corporate income tax matters.
The Goods and Services Tax/Harmonized Sales Tax (GST/HST) Rulings Division offers rulings and interpretations to explain technical GST/HST matters. You can find more information on GST/HST rulings and a list of the GST/HST ruling centres in publication RC4405, GST/HST Rulings – Experts in GST/HST Legislation, available at cra.gc.ca/E/pub/gp/rc4405. The provinces of British Columbia, Manitoba, Saskatchewan, and Quebec administer their own provincial sales tax (PST). I encourage you to write to these provinces to ask if they offer rulings on PST matters.
Thank you for writing. I trust the information I have provided is helpful.
Sincerely,
Geoff Trueman
Assistant Commissioner
Legislative Policy and Regulatory Affairs Branch
Canada Revenue Agency
George A Robertson, CPA, CMA
905-721-5196
2017-068349