28 April 1993 External T.I. 9305455 F - Advance Rulings

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ARC.

XXXXXXXXXX

Attention:  XXXXXXXXXX

Dear Sirs:

This is in reply to your letter dated February 15, 1993 wherein you requested additional information regarding the Department's advance income tax ruling service. Due to the large dollar values involved in your specific series of transactions, your professional advisors have recommended that you apply for an advance income tax ruling. However, you have indicated that you do not wish to proceed with your proposed series of transactions if material fees are involved.

Confirmation with respect to proposed transactions involving specific taxpayers will only be provided in response to a request for an advance income tax ruling. We have enclosed a copy of Information Circular 70- 6R2 dated September 28, 1990 and the Special Release thereto dated September 30, 1992 which sets out the guidelines under which advance income tax rulings are issued. The current hourly fee charged for advance income tax rulings is $95 (plus Goods and Services Tax) and a deposit of $481.50 equal to five hours of work plus Goods and Services Tax is required with a taxpayers ruling submission. The amount of time required to consider a request for an advance income tax ruling will depend on many factors, including the complexity of the series of transactions, the completeness of the submission and whether the Department has previously considered the particular issues involved in the ruling request.

Consequently, we regret that we are unable to provide you with an estimate of the hours that would be charged to your particular submission.

Instructions on how to submit a request for an advance income tax ruling can be found in paragraph 15 of the Information Circular. A submission which includes all of the information detailed in that paragraph will minimize the number of hours required to consider the particular advance income tax ruling request.

We hope that the above information will be of help to you.

Yours truly,

for DirectorReorganizations and Foreign DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch