Invalid and revoked advance income tax rulings

When there is a material omission or misrepresentation in the statement of relevant facts or proposed transactions submitted by the taxpayer or the taxpayer's authorized representative, the advance income tax ruling will be considered invalid and the CRA will not be bound by it.

Where an advance income tax ruling is issued covering a continuing action or series of actions or where the transactions are not yet completed and it is subsequently determined that the ruling is in error, it may be revoked. The revocation will not be made retroactively but will apply only to those actions or transactions which take place after the date of revocation.

The Directorate will give the taxpayer written notice of an intention to revoke an advance income tax ruling and the opportunity to make representations before a decision is made. A revocation is effected by written notice to the taxpayer to whom the ruling was issued.