Income Tax Severed Letters - 2022-08-03

Technical Interpretation - External

16 June 2022 External T.I. 2019-0819951E5 - AIIP - renovations to property

Unedited CRA Tags
1104(4), 1104(4.1)
Summary Under
Tax Topics - Income Tax Regulations - Regulation 1104 - Subsection 1104(4)
a renovation or alteration made to a depreciable property may qualify as accelerated investment incentive property

Principal Issues: Whether alteration or renovation costs incurred after November 20, 2018, to a depreciable property originally acquired in a taxation year ending prior to November 21, 2018 are accelerated investment incentive property.

Position: Renovation and alteration costs incurred after November 20, 2018, may be AIIP.

Reasons: Provided no CCA has been claimed on the particular renovation or alteration, costs incurred after November 20, 2018 should generally meet the conditions of paragraph (a) and paragraph (b), due to subsection 1104(4) or subsection 1104(4.1) of the Regulations

9 June 2022 External T.I. 2020-0836331E5 - Ontario Energy and Property Tax Credit

Unedited CRA Tags
Ontario Taxation Act, 2007: 98, 103.2(1), 103.9(2), (3), and (4), 103.10, 103.10(2), 103.10(3), 103.11, 104.1(1.2.1), 104.1(3); Ontario Municipal Act, 2001 349.

Principal Issues: What amount should be entered in box 61210 on Form ON-BEN?

Position: For the electricity component of the home energy costs, an individual should enter the total amounts paid to the supplier, as per their electricity bills, in box 61210 on Form ON-BEN.

Reasons: Eligibility rules in Taxation Act.

7 June 2022 External T.I. 2019-0796641E5 - Stock options issued to a corporation

Unedited CRA Tags
7(1); 9(1);
Summary Under
Tax Topics - Income Tax Act - Section 9 - Timing
stock options may not generate business income until they vest

Principal Issues: When should the unrealized benefit of the stock options issued to a corporation for services rendered be recognized in income for tax purposes under the Act?

Position: Depends on the facts of the situation.

Reasons: See below.