Advance Rulings regime: binding determinations for non-resident transactions with specified procedure and voiding for fraud. Chapter XIX-B establishes an advance rulings regime: definitions for applicant, application and Authority; constitution and staffing of the Authority for ... Summary
Advance Rulings regime: binding determinations for non-resident transactions with specified procedure and voiding for fraud.
Chapter XIX-B establishes an advance rulings regime: definitions for applicant, application and Authority; constitution and staffing of the Authority for Advance Rulings; application mechanics including form, fee, quadruplicate filing, transmission to the Commissioner, opportunity to be heard, and a six-month pronouncement period; grounds for rejection and requirement to give reasons; binding effect limited to the applicant, specified transaction, and the Commissioner/subordinate authorities; voiding for fraud or misrepresentation; and civil-court powers and procedural autonomy for the Authority.
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