Principal Issues: Can the CRA provide some information about the results of the ITRD internal evaluation process?
Position: General information provided.
Reasons: See below.
FEDERAL TAX ROUNDTABLE, OCTOBER 7, 2021
APFF CONFERENCE 2021
Question 20
Internal evaluation – Income Tax Rulings Directorate
We understand that the ITRD has recently undergone an internal evaluation of its services.
Question to the CRA
Can the CRA provide information on the results of that internal evaluation?
CRA Response
The recent internal evaluation of the ITRD was undertaken to assess the extent to which its program is achieving its intended results and to identify options for improving the services it provides. During this process, the CRA's Audit, Evaluation and Risk Branch interviewed ITRD staff, representatives of the tax community, officers of similar programs in other jurisdictions, and users of ITRD services. Its report entitled "Evaluation - Income Tax Rulings Directorate" was released in June and contains two recommendations to better enable the ITRD to achieve its objectives.
The CRA would like to thank all those who responded to the evaluation team's requests for feedback. The results of the evaluation are an important source of information and will help to improve the ITRD's services.
The results of the evaluation showed that although users of the ITRD's services are generally satisfied with its staff and the quality of the interpretative positions issued, the speed with which those positions are issued is a concern. This is also a concern for the ITRD, as delays in responding to requests may lead some people not to use the ITRD's services. To address this, the ITRD is currently reviewing its service model and priorities to identify options to reduce the processing time for requests for advance tax rulings and technical interpretations. Further information will be provided as the process moves forward.
It was also recommended that the ITRD change its performance measurement practices to be more transparent and responsive to client expectations. In response to that recommendation, the ITRD will take steps to increase the visibility of the results of its advance ruling and interpretation services. To that end, the ITRD will use Information Circular IC70-6R to communicate the results of its services for this and future years. Thus, starting next year, that publication will provide information on the ITRD's current service offerings and the frequency with which the ITRD met its advance income tax ruling and technical interpretation targets for the previous year.
Similarly, the ITRD will reinstate the practice of sending post-consultation surveys after issuing an advance ruling or technical tax interpretation. That will allow for the monitoring of new service requirements. The ITRD plans to implement that practice next spring. However, it may be delayed if clients express a desire not to receive those surveys while they are still dealing with the impact of the pandemic on their work.
Nathalie Aubin
(438) 340-0531
October 7, 2021
2021-091049
FOOTNOTES
Due to our system requirements, footnotes contained in the original document are reproduced below:
1 CANADA REVENUE AGENCY, Assessment - Income Tax Rulings Directorate, March 2021 (online: https://www.canada.ca/en/revenue-agency/programs/about-canada-revenue-agency-cra/internal-audit-program-evaluation/internal-audit-program-evaluation-reports-2021/evaluation-income-tax-rulings-directorate.html).
2 CANADA REVENUE AGENCY, Information Circular IC70-6R11 "Advance Income Tax Rulings and Technical Interpretations" April 1, 2021 (the version in effect at the time of writing) (online: https://www.canada.ca/en/revenue-agency/services/forms-publications/publications/ic70-6/ic70-6-advance-income-tax-rulings-and-technical-interpretations.html).