CRA is expanding the circumstances in which it may be prepared to issue rulings on factual matters

The Rulings Directorate is open to expanding situations in which it may issue rulings on matters that are primarily factual, provided that the taxpayer provides complete details and credible documentation to support those facts. Potential subject matters include:

• Transactions or arrangements involving crypto assets.
• Certain capital gains exemption issues, including shares’ qualification as QSBC shares.
• Whether expenditures are CEE.
• Taxability of distributions made by an Indian band to members.
• Whether distributions made by a non-profit organization disqualify it as such.
• Whether an organization has been organized as an NPO.
• Whether s. 149(1.2) allows an entity earning certain income outside its geographical boundaries to retain its exempted status under ss. 149(1)(d.5) and (d.6).

The Directorate is not currently considering rulings on the Global Minimum Tax Act given that its interpretation entails coordination with Canada’s tax partners.

Neal Armstrong. Summary of 2 December 2025 CTF Roundtable, Q.13 under General Concepts - Audit, Filing and Assessment Procedure.