The Rulings Directorate will stop gaming by taxpayers to get into the ATR queue by submitting an incomplete application

The Rulings Directorate has indicated that it will now:

• Close an ATR file where the ATR request is not properly prepared or supported with adequate representations or where the taxpayer has not responded to a request for additional information within 30 calendar days. …

The goal of this key change is to thwart taxpayers from hurriedly submitting an incomplete submission in order to get an advantageous “spot in the queue”. Once an ATR file is closed, a follow-up submission will not receive any greater priority than any other ATR requests.

Among other changes mentioned, there is targeted to be “a meeting with taxpayers to be held no later than within four weeks of receipt of an ATR request.”

Neal Armstrong. Summary of 5 December 2017 Roundtable, 2017-0734831C6 - 2017 TEI – Q. B5 under s. 152(1).