CRA confirms that transferring Class 14.1 property under s. 98(3) eliminates any additional Reg. 1100(1)(c.1)(i) CCA claims

Regarding where a taxpayer acquired Class 14.1 property after 2016 pursuant to an s. 98(3) rollover, CRA noted that, for taxation years ending before 2027, Reg. 1100(1)(c.1)(i) allows a claim of additional CCA of 2% on a portion of the undepreciated capital cost of Class 14.1 property of the taxpayer at the beginning of January 1, 2017. CRA effectively noted that there is no continuity rule regarding the transfer of Class 14.1 property under an s. 98(3) rollover, so that such a transfer would result in the loss of the additional CCA claims. 2017-0729871E5 makes essentially the same point regarding the s. 85 rollover.

Neal Armstrong. Summary of 13 March 2023 External T.I. 2019-0802271E5 F under Reg. 1100(1)(c.1).