Principal Issues: 1. General information on rulings and technical interpretations.
Position: 1. No position taken.
Reasons: 1. Service related letter.
August 20, 2013
XXXXXXXXXX
Dear XXXXXXXXXX:
Your member of Parliament, XXXXXXXXXX, sent my predecessor, the Honourable Gail Shea, a copy of your correspondence, which she received on June 20, 2013, about the response you received from the Income Tax Rulings Directorate (ITRD) of the Canada Revenue Agency (CRA).
The ITRD's letter of May 2, 2013, responded to your request for a technical interpretation on an income tax matter relating to one of your clients.
I regret that the ITRD's service was not helpful to you in assisting your client. Ms. Eliza Erskine, Director of the Business and Employment Division of the ITRD, will contact you to discuss your concerns and your technical enquiry. If you have any questions, you can reach Ms. Erskine at 613-957-2089. The CRA accepts collect calls.
The CRA provides many services to taxpayers and their advisors to help them correctly file tax returns. Among other things, the CRA offers information on its Web pages, in its income tax folios, and in its various guides. As well, taxpayers can call the CRA's telephone enquiries service.
The ITRD helps taxpayers and tax practitioners with more complex questions about the Income Tax Act that the CRA's telephone enquiries service cannot answer. The ITRD issues taxpayer-specific, advance income tax rulings for proposed transactions as well as general technical interpretations on the provisions of the Act.
Technical interpretations are meant to give taxpayers and their advisors information that will help them file their tax returns. These interpretations do not confirm how tax is applied in taxpayers' particular situations. If the request for a technical interpretation relates to a specific proposed transaction, an advance income tax ruling rather than a technical interpretation must be requested.
Although the CRA tries to meet the needs of all taxpayers and their advisors, the Canadian tax system relies on self-assessment because it is not possible to review the facts of every taxpayer's situation before he or she files a tax return. The CRA values and acknowledges the important role of tax practitioners in the Canadian tax system and the assistance they give taxpayers.
I trust that the information I have provided is helpful.
Yours sincerely,
Kerry-Lynne D. Findlay PC, QC, MP
c.c.: XXXXXXXXXX
Eliza Erskine
(613) 957-2089
2013-049449