Income Tax Severed Letters

This Week's Release

Technical Interpretation - External

15 September 2020 External T.I. 2020-0854471E5 - Pension Corporation - Renting Furnished Apartment

Unedited CRA Tags
149(1)(o.2)
the purchase and rental of furniture in a furnished apartment is assimilated to the apartment rental activity
Words and Phrases
activity
renting furnished apartments was an exclusively real-estate leasing activity

Principal Issues: Whether the ownership of furniture used to furnish rental apartment units for students is a distinct activity separate from the activity of leasing real property in contravention of the activity restriction in clause 149(1)(o.2)(ii)(A).

Position: No, provided that the furniture is ordinarily and customarily found in rental apartment units for students.

Reasons: Prior CRA positions with respect to the rental of furnished premises, and when separate activities may be viewed as an integrated whole.

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