In indicating that it “will generally not issue an advance income tax ruling … with respect to a limited partnership financing arrangement involving the application of the at-risk rules in the context of a tax shelter, as defined in subsection 237.1(1),” CRA stated:
Although the CRA does not verify the representations of fact at the time of the Ruling, they should be capable of verification at that time. The CRA is concerned that in these arrangements there are crucial aspects, such as arm's length issues, impact of future events, or other significant questions of fact, about which there is a level of uncertainty which does not lend itself to the provision, in advance, of a binding commitment by the CRA to view the tax consequences in a particular manner.