CRA acknowledges that s. 18(3.1) does not require capitalization of repair or maintenance expenses incurred during a renovation

When asked if it agreed with Janota (a light-weight case cited for the proposition that s. 18(3.1) applies only to the capitalization of soft costs), CRA was somewhat non-commital, but acknowledged that "the general expenses of repair and maintenance which are incurred during the period of Construction [defined to include renovation or alteration] of a building but which are otherwise not related to such Construction do not come within subsection 18(3.1)."

By the way, a glitch in the translation of Q. 12 (where s. 55(2.1)(a) was rendered as s. 55(3)(a)) has been corrected.

Neal Armstrong. Q. 3 of 9 October APFF Roundtable under 2015 APFF Conference.