Current income tax interpretation bulletins (ITs)

• ITs do not have the force of law
• Draft vs. final publications
• Complete review of an IT
• Consolidated IT

ITs do not have the force of law

At the Canada Revenue Agency (CRA), we issue income tax interpretation bulletins (ITs) to provide technical interpretations and positions regarding certain provisions contained in income tax law. Due to their technical nature, ITs are used primarily by our staff, tax specialists, and other individuals who have an interest in tax matters. For those readers who prefer a less technical explanation of the law, we offer other publications such as tax guides and pamphlets.

While the comments in a particular paragraph in an IT may relate to provisions of the law in force at the time they were made, these comments are not a substitute for the law. The reader should consider the comments in light of the relevant provisions of the law in force for the particular taxation year being considered, taking into account the effect of any relevant amendments to those provisions or relevant court decisions occurring after the date on which the comments were made.

Subject to the above, an interpretation or position contained in an IT generally applies as of the date on which it was published, unless otherwise specified. If there is a subsequent change in that interpretation or position, and the change is beneficial to taxpayers, it is usually effective for future assessments and reassessments. If, on the other hand, the change is not favourable to taxpayers, it will normally be effective for the current and subsequent taxation years or for transactions entered into after the date on which the change is published.

Draft vs. final publications

Once the technical content of ITs and ITTNs has been finalized, these publications are posted in draft form on the CRA's Web site with the word "Draft" on them, e.g. IT-178R - Draft and Income Tax Technical News No. 25 Draft. This makes the publications available to the public as soon as possible. They are then reviewed for possible minor editing and formatting changes. The changes, which rarely affect the substance of the content, are included in the final version of the publication. When this version is posted on the CRA's Web site a few weeks later, the word "Draft" no longer appears on the publication.

Complete review of an IT

When there has been a complete review of all paragraphs of an IT, the number identifying the IT changes, e.g., IT-178 becomes IT-178R and upon subsequent review becomes IT-178R2. The Explanation of Changes section at the end of the IT indicates the paragraph numbers that have been changed as a result of the review and provides a short explanation of the reasons for the changes.

Consolidated IT

In some situations, such as when there has been a substantial change in the law or a significant court case, only certain paragraphs of an IT are revised in order to update it as quickly as possible. When such is the case, the word "(consolidated)" will appear at the end of the IT number, e.g., IT-178R3 (consolidated). The paragraphs that have been revised by the current consolidation are identified at the front of the IT beside the heading Latest Revisions. The reasons for all of the changes made since the last complete review of the IT are indicated in the Bulletin Revisions section at the end of the IT. The date of the revision appears after the description of each change.