Reliance on severed or published advance income tax rulings

Advance income tax rulings are released to the public for information purposes only. In relying upon them, taxpayers must exercise caution. Such rulings can be relied upon only if the facts are identical to the proposed transactions, and similar transactions often have different facts.

It should also be noted that many material facts may be severed during the course of preparing a ruling for release to the public to protect the taxpayer's identity. Therefore, taxpayers should request an advance income tax ruling to confirm the income tax consequences of their particular proposed transactions.

Taxpayers should also exercise caution to ensure that none of the relevant Income Tax Act provisions, case law interpreting those provisions or CRA interpretations has changed. The CRA will not amend published advance income tax rulings or severed advance income tax rulings for subsequent changes in law or interpretation.