We understand that rulings on subsection 245(2) are limited in scope to the tax consequences described in such rulings.
Will RCT allow taxpayers to review the draft of such rulings prior to finalization to ensure adequate descriptions are given of such tax consequences?
Answer
To enable the Department to determine whether or not the provisions of subsections 245(2) of the Act apply with regard to any of the transactions proposed, the ruling application should contain a complete description of the purpose or purposes of each proposed transaction. The submission of this information should result in the tax consequences of the proposed transactions having been thoroughly considered and should make a review of a draft ruling unnecessary.
Tax Executive Institute - January 11, 1990Question #12Prepared by: A.A. Cameron