4 November 1981 Income Tax Severed Letter 5-3325 - [Paragraph 15.1(3)(f) of the Income Tax Act]

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ARC.

J.G. Luck 613-593-6937

XXXX

November 4, 1981

Dear XXXX

This is in reply to your letter dated October 9, 1981 concerning specified property within the meaning of paragraph 15.1(3)(f) of the Income Tax Act (the Act).

In order that a corporation be entitled to issue a small business development bond (SBDB) in respect of the cost of a particular depreciable property, the property must be acquired by the issuer after December 11, 1979 and before 1982. Paragraph 7 of Interpreta- tion Bulletin IT-50R states, in part, that the owner of a building under construction is considered to have acquired the building at any particular time to the extent of the construction costs incurred by him to that time or the progress billings received by him to that time, as the case may be.

Accordingly, a corporation may issue an SBDB in respect of costs incurred or progress billings received after December 11, 1979, but before 1982, provided, of course, all other requirements of section 15.1 are satisfied.

Yours truly,

for Director Specialty Corporations Rulings Division Corporate Rulings Directorate Legislation Branch