SECTION 55 – RULINGS ON THE PURPOSE TEST
In a December 5, 2017 Technical Interpretation (2017-0723491C6, Ton-That, Marc), CRA reiterated that while they do not usually issue Advance Income Tax Rulings in primarily factual determinations, they will consider issuing a favourable ruling under Subsection 55(2) where circumstances support the absence of one of the purposes described in Paragraph 55(2.1)(b). CRA also reiterated a comment from 2016 which stated that other than rulings on loss consolidations, they have not been deluged by requests for rulings on this topic.
For further information see Video Tax News Monthly Tax Update Newsletter, Issue No. 442