Initiative aims to support large investors and projects: Canada Revenue Agency
François-Philippe Champagne, federal finance and national revenue minister, has announced that the Canada Revenue Agency (CRA) is prioritizing advance income tax ruling requests relating to investments of at least $1 billion in Canada, effective immediately.
The new measure is part of the advance income tax rulings (AITR) program, established over five decades ago. The CRA said the new initiative, announced ahead of the Investment Summit, seeks to help major investors eyeing Canada:
- Seek a binding CRA decision on the application of Canada’s income tax law to a proposed transaction before committing capital
- Gain more clarity and predictability on how Canadian tax treatment will apply to their investment in a time of uncertainty
- Proceed with large projects in Canada with more confidence
- Reduce risks
- Have more information to back up financing decisions
"When investors are considering major projects, certainty matters,” Champagne said in the CRA’s news release. “By prioritizing advance tax rulings for investments of $1 billion or more, we are giving them the clarity and predictability they need to invest with confidence, create opportunities and help build Canada’s economic future.”
According to the CRA, the new measure also aims to:
- Help the government attract investments
- Generate well-paying jobs in Canada
- Improve the country’s long-term economic competitiveness
In the 2026 Spring Economic Update, the federal government shared its plan to prioritize AITR requests for large and nation-building projects, clean economy initiatives, productivity-enhancing investments, and other investments aligned with the country’s economic priorities. The CRA explained that the new initiative builds upon that measure.
About advance income tax rulings
The CRA’s news release noted that the AITR program seeks to help businesses, investors, and taxpayers:
- Get authoritative guidance on the Canadian income tax impacts of planned transactions
- Have binding confirmation on the applicability of the Income Tax Act, 1985
- Make informed decisions before significant transactions or investments
For AITR requests not eligible for prioritized access, the CRA confirmed that it will keep observing a 90-business-day service standard or a mutually agreed service target date for all AITRs.
In the fiscal year from Apr. 1, 2024, to Mar. 31, 2025, the CRA issued 91 percent of AITRs within the 90-business-day service standard or by a mutually agreed service target date.
More news on Canada Revenue Agency
Here are some other recent news stories involving the CRA.
While accepting that a taxpayer might have a good case for a payment plan, the Federal Court issued an Aug. 17 decision affirming the CRA’s denial of her request for relief from penalties and interest owed for taxes filed late.
On Aug. 13, the Federal Court declined to extend the time for a man to apply for judicial review of a CRA decision refusing his request to cancel his 2020–21 tax-free savings account taxes.
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