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On September 14, 2026, the Minister of Finance and National Revenue announced that the Canada Revenue Agency (CRA) will, as of now, prioritize advance income tax ruling (AITR) requests relating to investments of at least $1 billion in Canada. The news release, issued on the first day of the federal government’s Investment Summit, states that this change is intended to provide “the clarity and certainty [major investors] need to move forward with confidence to get projects built” by reducing risks and informing investors’ financing decisions.
AITRs allow taxpayers to request the CRA’s view of how specific provisions of the Income Tax Act (Canada) apply to a proposed transaction. Once issued, AITRs are binding on the CRA for the particular taxpayer (subject to stated requirements or caveats). The news release notes that AITRS provide “the highest level of tax certainty available from the CRA.”
The CRA aims to issue AITRs within 90 business days (over four months) of receiving the relevant information, or within an alternative target date mutually agreed upon with the taxpayer. The CRA met these target dates for 80% to 93% of the requests it received over the past three years. No information is available about how much longer the “mutually agreed” alternative target dates are, nor how much longer the requests that did not meet the targets took. In our experience, the process for obtaining an AITR can be lengthy, particularly for complex transactions involving significant amounts of money. For fast-moving transactions, even the standard four-month target can represent a significant delay.
The September 14 announcement follows a similar announcement on April 28, 2026, in the 2026 Spring Economic Update, that the CRA would give priority to AITR requests that relate to
- large-scale, nation-building projects (e.g., housing and infrastructure)
- projects of national importance
- “investments that enhance productivity and strengthen critical sectors of Canada’s economy” — specifically, clean economy initiatives and projects that may qualify for a clean economy ITC
The news release notes the new priority for $1 billion investments “builds on” the prior announcement in the 2026 Spring Economic Update, meaning significant investments of less than $1 billion in Canada may still qualify for priority treatment.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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