30 March 2011 External T.I. 2010-0390591E5 F - Cotisation spéciale -- summary under Subparagraph 248(16)(a)(i)

In the course of discussing the deductibility of an assessment made of the taxpayer by the other co-owners of a commercial condo complex to cover working capital needs, CRA stated:

GST paid or payable in respect of inventory or capital property is added to the cost of inventory or capital property, as the case may be. If the input tax credit was claimed in the return filed for the reporting period in which the tax was paid or became payable, that credit would generally be included in income because of subparagraph 248(16)(a)(i) or reduce the cost of capital property acquired under subparagraph 248(16)(a)(i), subsection 13(7.1), paragraph 53(2)(k) and paragraph 12(1)(x)(vi), as the case may be, at the same time as the tax paid or payable in respect of the expenditure or capital property.

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