30 August 1990 Income Tax Severed Letter ACC9225 - Deductibility of Utility Service Connection Cost

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.

Current Amendments and                        Head Office
  Regulations Division                        Rulings Directorate
B. Bryson                                     F.B. Fontaine
Acting Director                               957-2095

                                              900443

Paragraph 20(1) (ee) of the Income Tax Act (the "Act")

Further to our recent telephone conversation with Don Joy, we request your comments as to whether a utility service connection cost incurred in the circumstances described below should, in terms of fiscal policy, be deductible even though the payment was made to a person other than the person who supplied the service. A referral from the Mississauga District Office describes that

                        24(1)
                        21(1)(b)
We enclose a copy of our reply to the District Office for your
information and look forward to your comments in due course.

R.J.L. Read Director General Rulings Directorate Legislative and Intergovernmental Affairs Branch