Words and Phrases - "preparation or installation"
25 February 2026 External T.I. 2025-1081921E5 - Labour requirements - Preparation or Installation
In order to support a substantial piece of equipment described in Class 57(a) in respect of a carbon capture utilization and storage (CCUS) project, Canco will construct a concrete foundation, including the excavation of a hole, the installation of pilings, and the pouring of concrete. The CRA found that this foundation would qualify under Class 57(f) as a structure, substantially all of which was used in the installation of Class 57(a) equipment, so that the foundation would itself be a specified property as defined in s. 127.46(1). CRA then stated:
As a result, Canco would be subject to the labour requirements for the preparation or installation of the Foundation (a specified property), provided that Canco elects to meet the labour requirements under subsection 127.46(2). In our view, this would include the excavation of the hole into which the Foundation will be placed, the installation of the pilings and the pouring of the concrete to construct the Foundation [and] these activities … would constitute the “preparation or installation of specified property” for purposes of the labour requirements in section 127.46.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 57 - Paragraph 57(f) | cost of installing a concrete foundation would qualify under Class 57(f) | 228 |