Docket: 2007-706(IT)I
BETWEEN:
RÉAL DAOUST,
Appellant,
and
HER MAJESTY THE QUEEN,
Respondent.
[OFFICIAL ENGLISH TRANSLATION]
Appeal
heard on common evidence with the appeal of Nedjma Zidane
(2007-705(IT)I), on July 18, 2007, at Montréal, Quebec
Before: The Honourable
Justice Gaston Jorré
Appearances:
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For the Appellant:
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The Appellant himself
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Counsel for the Respondent:
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Susan Shaughnessy
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____________________________________________________________________
JUDGMENT
The appeal from the assessment made under
the Income Tax Act for the 2005 taxation year is allowed, without costs,
in accordance with the attached Reasons for Judgment, and the matter is
referred back to the Minister of National Revenue for reconsideration and
reassessment on the basis that $29,847 of the amount of $54,565 that the
Minister considered to be a capital expenditure is actually current in nature.
Signed at Ottawa, Canada, this 9th day of
June 2008.
"Gaston Jorré"
Translation certified true
on this 25th day of July 2008.
Brian McCordick, Translator
Docket: 2007-705(IT)I
BETWEEN:
NEDJMA ZIDANE,
Appellant,
and
HER MAJESTY THE QUEEN,
Respondent.
[OFFICIAL ENGLISH TRANSLATION]
Appeal heard on common evidence with the
appeal of Réal Daoust
(2007-706(IT)I), on July 18, 2007, at Montréal, Quebec
Before: The Honourable Justice Gaston Jorré
Appearances:
|
For the
Appellant:
|
The Appellant himself
|
|
|
|
|
Counsel for the Respondent:
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Susan
Shaughnessy
|
____________________________________________________________________
JUDGMENT
The appeal from the assessment made under
the Income Tax Act for the 2005 taxation year is allowed, without costs,
in accordance with the attached Reasons for Judgment, and the matter is
referred back to the Minister of National Revenue for reconsideration and
reassessment on the basis that $29,847 of the amount of $54,565 that the
Minister considered to be a capital expenditure is actually current in nature.
Signed at Ottawa, Canada, this 9th day of June 2008.
"Gaston Jorré"
Translation certified true
on this 25th day of July 2008.
Brian McCordick, Translator
Citation: 2008TCC316
Date: 20080609
Dockets: 2007-706(IT)I
2007-705(IT)I
BETWEEN:
RÉAL DAOUST,
NEDJMA ZIDANE,
Appellants,
and
HER MAJESTY THE QUEEN,
Respondent.
[OFFICIAL ENGLISH
TRANSLATION]
REASONS FOR JUDGMENT
Jorré J.
Issue
[1] These appeals, both of which pertain to the
2005 taxation year, were heard on common evidence.
[2] The Appellants purchased a building in
July 2004, and had work done on it in 2005 and 2006. The issue is the
nature of that work. Were the expenditures current expenditures, which are
deductible in the year that they were made, or were they capital expenditures,
which are deductible by means of the capital cost allowance mechanism
contemplated in paragraph 20(1)(a) of the Income Tax Act and
Part II of the Income Tax Regulations?
Facts
[3] In the paragraph below, I will set out the
Respondent's assumptions of fact. I will add, in parentheses and in
italics, the Appellants' position with respect to each of those assumptions. In
Mr. Daoust's case, I am referring to his Reply to the Notice of Appeal.
[4] In making his decision, the
Minister relied on the following facts:
(a) The Appellant and his
spouse Ms. Nedjma Zidane are co-owners of, inter alia, the building
located at civic addresses 568 through 572 Théodore
Street in the city of Montréal. (admitted)
(b) The property in issue is a century-old triplex
built in 1900. (admitted)
(c) In respect of the taxation year in issue, the
Appellant claimed his 50% share of the rental loss from the operation of the
building bearing the addresses 568, 570 and 572 Théodore
Street in Montréal. (admitted)
(d) On July 22, 2004, the Appellant and Nedjma
Zidane purchased the building for $292,000. (admitted)
(e) The building was in good condition, and the
Appellant and his spouse paid the market price for it. (admitted)
(f) The municipal evaluation of the property at the
time of purchase was $164,900. (admitted)
(g) For the 2005 taxation year, the $56,956
"maintenance and repair" expense claim in respect of the property was
broken down in the following manner following an audit:
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(i) computation error
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$541
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(ii) capital expenditures
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$54,565
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(iii) disallowed expenditures
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$233
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(iv) allowed expenditures
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$1,617
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$56,956
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(The Appellant Daoust is not admitting that $54,565 in expenses
in point (ii) constitutes capital expenditures, but he is admitting the rest,
including the amount of $54,565.)
(h) An amount of $54,565, claimed as maintenance and
repair expense for the property at 568, 570 and 572
Théodore Street in Montréal
("the Montréal property") for the 2005 taxation year, was
for the following work:
(i) check the foundations and make the floor
level on the ground floor,
(ii) consolidate the foundations,
(iii) repair the brick cladding on two outer walls,
(iv) raise the balcony railings,
(v) roof membrane redone,
(vi) replace the electrical panels with
circuit-breaker panels,
(vii) install fire alarms,
(viii) redo the ventilation in the bathroom and
kitchen, and
(ix) wiring and plumbing of ground floor redone.
(The Appellant admits to this paragraph but adds the following
particulars: The work was done over a two-year period (2005 and 2006), the
work referred to in points (i) and (ii) was done in 2005, the work in point
(iii) commenced in 2005, and all the rest was done in 2006.)
(i) The supporting documents in relation to the
$54,565 claimed as maintenance and repair expenses in respect of the Montréal
property for the 2005 taxation year were examined, and a list was prepared (see
attachment). (admitted)
(j) The said $54,565 is part of a major renovation
program, sponsored by the Ville de Montréal and the Société d'habitation
du Québec. The program contemplated a total cost of $159,689 for work to be
done over a roughly 10‑week period on the Montréal property. (The
Appellant admits to the paragraph but adds that the work was done in late 2005
and early 2006.)
(k) One objective contemplated by the program is to
restore all components of the building in order to prevent the need for any
work, other than normal maintenance, for a period of 15 years. (denied)
(l) The program provides subsidies, but no subsidy
was paid to the Appellant and his spouse during the 2005 taxation year. (Admitted,
though the Appellant adds that he and his spouse, the Appellant Ms. Zidane,
received the subsidy in 2006.)
(m) An amount of $54,565, claimed as maintenance and
repair expenses in respect of the Montréal property for the 2005 taxation year,
was disallowed for the following reasons:
(i) the work provided an enduring benefit to the
building,
(ii) the renovation cost is very high in relation
to the building's value,
(iii) revitalization of a century-old building,
added rental value,
subsidy granted on the condition, inter alia, that the Ville
de Montréal [the municipal government] approve the leases, and
none of these facts result from work done as part of normal property
maintenance (denied)
(n) The capital cost allowance table for the
Montréal property was revised in order to include capital expenditures of
$54,565 before adjustments, and deduct such amount, on account of capital cost
allowance, as was necessary to cancel any income from the said property for the
taxation year in issue. (denied)
[5] There is no real disagreement on the facts.
The crux of the debate is the nature of the expenditures in question.
[6] The Appellants purchased the building, a
residential triplex, in 2004 with the intention of leasing the units. The
triplex was built in 1900.
According to Mr. Daoust, the building was in good condition.
[7] In the second year, the Appellants decided to
repair the brick cladding and asked for quotes. For better workmanship, it was
recommended that new bricks be used.
[8] The Appellants decided to apply for a subsidy
from a major renovation program sponsored by the Ville de Montréal and the
Société d'habitation du Québec. In order to be eligible for the program, one
must meet certain criteria and spend at least $15,000 per dwelling. In this
instance, the brick repairs opened the door to the subsidy.
[9] Eligibility for the program was subject to
other conditions as well. Mr. Daoust explained that the entire building
had to be restored in accordance with applicable regulations. Consequently, a
whole series of repairs had to be done.
[10] The work was described in Exhibit A‑4,
a quote, reproduced below:
1. EXTERIOR
WALLS 15,700 bricks x $0.55
1.1
Replace the
brick cladding on the alley side 2,100 ft.2 $10.00/ft.2
wall and back walls as indicated in the plans
Note: retain the horizontal alignment of the
openings
1.2 Replace
apron walls and rebuild lintels 6 $75.00
Note:
rebuild lintels, 11 inches high, with 6 $40.00
bricks
in soldier course and overhanging by
½
inch
Note:
the apron walls will be stone or concrete,
with
a water discharge 2 ½ inches high, and
will
extend past the opening by 4 inches
1.3 Note: submit a sample of the brick type for
prior
approval
1.4
Repair the brick
cladding (damaged bricks, 100 ft.2 $20.00/ft.2
hollowed joints) as indicated in the plans
Subtotal $32,175.00
DOORS
AND WINDOWS
2.1
Ventilate the
cellar using doubled 2 $100.00
gooseneck, 4 inches in diameter, with grills
and removable protective covers
2.2
Redo the sealing
joint around the doors 26 $60.00
and windows
Subtotal $1,760.00
OVERHANGS
3.1
Rebuild the
balcony floors in plywood 2 $815.00
covered with fiberglass
3.2 Raise
the balcony railings to 42 inches 44 LF $20.00/LF
Subtotal $2,510.00
4. ROOF
4.1
Lay new membrane
(4-ply felt, asphalt 1,400 ft.2
and gravel) and all flashing
4.2
Ventilate the
roof space using gooseneck
at 1 square foot every 300 square feet
4.3
Note: a copy of
the warranty for the new roof
(10
years) must be submitted to the Division
de soutien aux projets de
logement social et
abordable before the file is closed
Subtotal $8,000.00
5. CLEARING
AND DEMOLITION
5.1
Clear the
cladding from all walls and $500.00
ceilings in the unit on the ground floor
5.2
Remove all floor
covering $1,000.00
in
the unit on the ground floor
5.3
Demolish the
chimney down to the $360.00
roof decking
5.4
Remove the brick
cladding from the adjoining 2,330 ft.2 $4.00
alley side wall and from the back facades
as indicated in the plans
5.5 Strip
the balcony floors $54[illegible]
5.6 Demolish
the back shed $360
5.7
Remove cladding
from unit bathroom walls
and ceilings on the floors
5.8
Condemn the
chimney at the ground floor
5.9
Control:
If the demolition or stripping reveals a weakness
or deficiency in the structure or any other
component, immediately notify the service
representative to decide on the work to be
undertaken.
Cleaning:
Clean the site, inside and outside, as the
work progresses.
.
Safety:
block
the openings in accordance with regulations.
Health
and safety:
that
the Occupational Health and Safety
Regulations
are followed
Subtotal $16,080.00
6. STRUCTURE
AND FRAMING
building framing and foundation and
submit a copy of the report and/or plans
on the condition of the framing and foundation,
and, if necessary, the modifications to be made
6.2
Correct the
structure as indicated in the $6,750.00
engineer’s approved report
*no engineer’s plan on hand
6.3 Brick
up openings in the foundation wall 3 $125.00
Subtotal $712[illegible]
7. FLOORS
(SUBFLOOR AND FLOORING)
7.1
Cover all floors
on the ground floor with 1,400 ft.2 $3.00/
ft.2
1/2-inch plywood nailed every 6 inches
centre to centre along the edges and
every 8 inches centre to centre everywhere
else
7.2
Lay ceramic tile
with marble thresholds on 252 ft.2 $7.00/ft.2
bathroom and kitchen floors on the
ground floor
*If crawlspace electrical panels need to be
moved temporarily for underpinning work,
additional costs will apply.
7.3
Lay select
yellow birch parquet (or approved 1,150 ft.2 $7.00
equivalent) on the ground floor as indicated
in the plans
Subtotal $15,014.00
8. ROUGH
CARPENTRY
to centre) on exposed walls in the ground floor
unit
8.2
Refit the rooms
in the unit on the ground
floor in accordance with the project plans 1 $1,760.00
accepted by the person in charge of grants and
renovations (new divisions in 2 in. x 4 in. to
16 in. centre to centre)
Subtotal $3,640
9. ELECTRICITY
[illegible]
breaker panels. The existing lines are
sufficient
9.2
Install:
- outlets with breakers in building bathrooms
- counter outlets in ground floor kitchens (on
an independent circuit)
- electrical outlets wherever needed on the
ground floor
- range outlets on the ground floor
- washer/dryer outlets on the ground floor
9.3
Install ceiling
fixtures in building bathrooms
and ground-floor corridors and kitchens
9.4
Install adequate
electric heating (baseboard)
with a wall thermostat in each unit room
9.5
Install an
outside ventilation hood above the
ranges (220 cubic feet per minute minimum)
in each unit
9.6
Install mechanical
ventilation in all bathrooms
(110 cubic feet per minute minimum) in each
unit
9.7
Install a
110-volt (A.C.) automatic smoke
detector near the bedrooms in each
unit
9.8
Install all
telephone and television cables in
the unit on the ground floor
Subtotal $4,500.00
or
$7,500.00
10. MECHANICS
AND PLUMBING
new fixtures: kitchen sink, bathtub with
shower enclosure, sink, toilets with insulated
tank and seat
10.2
Install
connections for the washer on
the ground floor
10.3
Install rigid
exhaust ducts leading outside
for mechanical ventilation in bathrooms,
range hoods and dryers
Subtotal $4,400.00
11. SOUNDPROOFING
stacks on the ground floor
11.2
In the ceilings
separating the occupied 1,400 ft.2 $2,500.00
areas, install resilient bars, 16 in. centre
to centre, and acoustical wool, 3 ½ in.
(5/8 in. type X plasterboard; see
section 13 – interior cladding)
Subtotal $2,570.00
12. THERMAL
INSULATION
Subtotal $4,400.00
13. INTERIOR
CLADDING
and ceilings on the ground floor
Note: ½ in. type X plasterboard on all
load-bearing walls. 5/8 in. type X plasterboard
on walls separating housing units from one
another and on walls separating housing
units from common areas. 5/8 in. type X
plasterboard on all ceilings required to be
fire-resistant.
13.2
Rebuild the
interior cladding on the walls
and ceilings of the bathrooms on the floors
Note: water-resistant plasterboard in bathrooms
13.3
Repair the
interior cladding on walls and 4,500 ft.2 [illegible]
ceilings following plumbing, electrical and
ventilation work, and in other areas, as
necessary
Subtotal $495
14. TRIM
FINISHING
14.1
Replace all
baseboards, quarter round and 800 LF $1,500.00
framing on doors and windows on the
ground floor and in bathrooms on the floors
14.2 Replace the interior doors on the ground floor 18 $150.00
each
Subtotal $4,200.00
15. CABINETS
AND VANITIES
15.1
Install cabinets
in the kitchen on the ground 1 $4,000.00
floor, as shown in the approved plans
(minimum counter space of 2.5 square feet
per housing unit and storage space of
10.5 cubic feet per housing unit)
15.2 Install
cabinets above washers and dryers 1 $250.00
15.3 Install
a vanity under the sink in bathrooms 1 $250.00
Subtotal $4,500.00
16. BATHROOMS
16.1
Install ceramic
tile on the walls around 60 ft.2 [illegible]
bathtubs at least 6 feet above the tub, and
exceed the tub area by one tile (provide
for bathroom accessories: roll holder,
towel holder, soap holder, curtain rod, etc.)
16.2
Install a
recessed medicine cabinet in 1 $135.00
bathrooms
Subtotal $495.00
17. PAINT
17.2
Repaint the
walls and/or ceilings where
repairs have been made, and other areas
as necessary (2 coats)
17.3 Paint all exterior building projections (2 coats) $4,000.00
17.4 Clean the units and common areas prior
to delivery 1 $300.00
Subtotal $6,800.00
If you wish to have the work covered by a guarantee plan,
contact the
Association provinciale des
constructeurs d’habitation du Québec (APCHQ) at 514‑353‑1120.
RENOVATION QUEBEC PROGRAM
APPLICATION
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Building 568-572 Théodore Street
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Postal
code
[illegible]
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Telephone
514-765-8747
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Signature:
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Date
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Application
valid for 30 days
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Indicate the subtotal for each
section of the work program
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This space reserved for the City
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$1,760.00
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$2,510.00
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$8,000.00
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$16,080.00
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$7,125.00
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$15,014.00
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$3,460.00
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$4,500.00
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$4,400.00
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$2,570.00
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$4,400.00
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$4,950.00
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$4,200.00
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$4,500.00
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$495.00
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$6,800.00
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+10%+7%+7.5%
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$122,939.00
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Total
before taxes and profit
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Total
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$155,551.64
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[11] Exhibit I-1, the agreement with the
contractor, provides some additional details, but is not as detailed as Exhibit
A-4. Moreover, the agreement stipulates one overall price and does not break
down the amounts for the different work to be done. I would note that
there is a small price difference between Exhibits A‑4 and I‑1.
The total amount quoted is $155,551.64,
whereas the price contemplated in the agreement is $159,689.08 and includes an
amount of $8,000 payable on signing (2005) and an amount of $40,000 payable
when the work begins (in 2005).
[12] Mr. Daoust testified that most of this
work could have been spread out over a period of several years, but that, in
order to meet the requirements of the major renovation program, the Appellants
had to do all the work at the same time.
[13] The work can be divided into three major
categories:
(a) complete renewal of
the exterior brick walls;
(b) work stemming from the
fact that the ground floor was too sloped;
(c) miscellaneous work,
such as painting of exterior overhangs, soundproofing, thermal insulation and
replacement of the fuse boxes with circuit-breaker panels.
Analysis
[14] In accounting, the role of depreciation is to
spread out, over several years, the deduction of expenses that will be
useful to a business for several years in order to provide a more accurate idea
of the benefits.
[15] Where the expenses will provide a benefit that
will last several years, the purpose of categorizing certain of them as
capital expenditures is similar to the purpose of the capital cost allowance
contemplated in paragraph 20(1)(a) of the Income Tax Act, even
though the accounting and taxation mechanisms differ from each other.
[16] The case law regarding the distinction between
a current expense and a capital expenditure is extensive. In Bergeron
et al. v. M.N.R.,
Judge Lamarre Proulx considered that case law:
The principles I draw from these cases are the following:
- income-related expenses include repairs the purpose of which is to
make the part or the property repaired suitable for normal use again;
- capital expenses include work the purpose of which is to replace
an asset by a new one and work which involves such a degree of improvement to
an asset that it becomes a new one. This asset must have significant value
compared to the rest of the property or be an asset in itself; work to change
the use of premises or a room or to add new premises or a new room is usually
capital in nature; the same is true of a change in the heating system;
- although the factor of recent purchase is not significant when
there is no change of use, the increase in value of the real property over the
purchase price, as a result of the repairs, is an indication that the cost or
part of the cost of the expenses is in the nature of the purchase price of
property;
- expenses must also be reasonable in the circumstances (section 67
of the Act): the question is whether they were reasonably incurred to derive
income or to increase the value of the property, and in what proportion; future
profits can be taken into account if the expenses in question reduce subsequent
expenses1 and also I suppose the unforeseen scale of the costs.
1 Halsbury's
Laws of England, 4th
ed., vol. 23, para. 310.
[17] In Johns-Manville Canada Inc. v. The Queen, a decision of
the Supreme Court of Canada, Estey J. wrote as follows, at paragraphs 31 and
32:
31 We must also remember the previously cited words of Lord
Pearce in B.P. Australia Ltd., supra, at p. 264:
It is a commonsense appreciation of all the guiding features which
must provide the ultimate answer.
32 . . . The same judge in Hallstroms Pty. Ltd., supra,
at p. 648, reminds us that the classification of such expenditures "...
depends on what the expenditure is calculated to effect from a practical and
business point of view, rather than upon the juristic classification of the
legal rights. . . . "
[18] In light of these principles, certain work can
be characterized as repairs and is therefore current in nature, whereas other
work is capital in nature. Given the scope of the work, some of it consists of
improvements, and the rest constitutes repairs.
The brick walls
[19] The work on the brick walls involved the
complete replacement of old walls with new ones. The old lane-side and rear
walls of the building were completely removed and rebuilt using new bricks.
Thus, the work described in sections 1.1 to 1.4 and 5.4 consists of
capital expenditures, which amount to $41,495.
[20] I would note that the facts of the instant
case are different from those in Di Fruscia v. The Queen, where Rip
A.C.J. stated as follows at paragraph 9 of his decision:
The repair of a floor is a current expense. There is no addition of
an asset. An old asset, because of its use, has been repaired.[4]
Similarly, the replacement of bricks to the exterior wall of a building is a
repair. No wall is being replaced. Old, damaged brick has been replaced
by new bricks to make the building suitable for normal use.[5]
[4] See Canada
Steamship Lines Limited v. M.N.R., 66 DTC 5205, at p. 5207, per Jackett
P.
[5] Gold Bar Developments Ltd. v. Canada, [F.C.T.D., T-952-85, March 5, 1987], 87 DTC 5152.
[Emphasis added.]
In the instant case, two outer walls of a house built
in 1900 were completely removed, and two completely new walls were built in
their place. That expense will endure for a very long time.
Repairs related to the excessively sloped ground floor
[21] This work merely levelled the floor and the
ground-floor unit.
The expenditure is therefore a current one.
The other expenditures
[22] The other expenditures are varied.
I will list those that are capital in nature.
(a) the electrical work
(Exhibit A-4, items 9.1 to 9.8) constituted improvements: for example,
circuit-breaker panels were installed instead of fuse panels, and a ventilation
system and smoke detectors were installed; this work totalled $7,500;
(b) soundproofing, at a
cost of $2,570 (Exhibit A-4, item 11);
(c) insulation, at a cost
of $4,400 (Exhibit A-4, item 12);
(d) ventilation of the
basement at a cost of $200 (Exhibit A-4, item 2.1); and
(e) raising the balcony
railings to 42 inches, at a cost of $880 (Exhibit A-4, item 3.2).
The remainder of this group of expenditures is current
in nature.
The agreement
[23] Although the quote (Exhibit A-4)
provides the details of the different work, the agreement stipulates an
overall amount that is not broken down into the different tasks. Moreover,
the amount of the contract is somewhat different, and simply contemplates payments
(a) upon signing,
(b) upon commencing the
work,
(c) mid-way between the
commencement and completion of the work,
(d) upon commencing the
finishing work, and
(e) upon completion.
An amount of $48,000 was paid in 2005, and the
rest was paid later.
[24] Consequently, the payments cannot be broken
down by specific job. The capital portion of the payments must be deemed
to be a prorated amount of the total.
[25] Since the total amount of the quote
was practically identical to the contract amount, one can simply use the quote
to calculate the percentage of expenditures that were capital in nature. The
capital expenditures listed in paragraph 19 and 22, supra, amount to
$57,045, before taxes and profits.
This represents approximately 45.3% of the costs.
Conclusion
[26] In view of the circumstances, 45.3% of the
amount of $48,000 paid to the contractor must be considered a capital
expenditure, and 54.7% of that amount must be considered current in nature. In addition to
the amount of $48,000, there is an additional $6,565 on account of expert fees,
architect's fees, notary's fees, application processing fees and permit fees
incurred in order to enable the Appellants to qualify for the major renovation
program which subsidized the work.
Since these expenditures were essential to the entire project's
realization, this amount must be allocated between current and capital
expenditures in the same fashion.
[27] Consequently, the appeals are allowed, without
costs, and the matters are referred back to the Minister of National Revenue
for reconsideration and reassessment on the basis that $29,847 of the amount of
$54,565 which the Minister considered to be a capital expenditure was actually
current in nature.
Signed at Ottawa, Canada, this 9th day of June 2008.
"Gaston Jorré"
Translation
certified true
on this 25th day
of July 2008.
Brian McCordick,
Translator
CITATION: 2008TCC316
COURT FILE NOS.: 2007-706(IT)I,
2007-705(IT)I
STYLE OF CAUSE: RÉAL DAOUST v. HER MAJESTY THE QUEEN, NEDJMA ZIDANE v. HER
MAJESTY THE QUEEN
PLACE OF HEARING: Montréal,
Quebec
DATE OF HEARING: July 18, 2007
REASONS FOR
JUDGMENT BY: The Honourable Justice Gaston Jorré
DATE OF JUDGMENT: June 9,
2008
APPEARANCES:
|
For the
Appellant:
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The Appellant himself
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Agent of the Appellant:
|
Réal Daoust
|
|
|
|
|
Counsel for the Respondent:
|
Susan
Shaughnessy
|
COUNSEL OF RECORD:
For the
Appellants:
Name:
Firm:
For the
Respondent: John H. Sims, Q.C.
Deputy
Attorney General of Canada
Ottawa, Canada
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