29 October 1991 Memorandum (Tax Window, No. 12, p. 13, ¶1557)

Cost incurred in obtaining an advance income tax ruling will be deductible if they relate to a business of the taxpayer and the transactions in question are of an income nature. It is RC's practice to accept the cost of obtaining a ruling as a cost relating to the business even though there may be arguments that the proposed transactions themselves do not relate to a business carried on by the taxpayer.

The costs incurred in obtaining an advance income tax ruling which are deductible include legal and accounting fees incurred to prepare the ruling request, the cost of attending interviews with rulings officers, and the fee charged by Revenue Canada for the ruling, but do not include transaction costs which would have been incurred even if no ruling had been requested.