11 June 2010 External T.I. 2010-0354881E5 F - Traitement fiscal de la FNACC -- summary under Subsection 20(16)

Where a Canadian film and video production ("CFVP") that was included in Class 10 no longer generates income, how is the balance of the undepreciated capital cost ("UCC") of the class to be treated? After referring to s. 45, CRA stated:

[I]f the CFVP ceases to be used to earn income, the corporation is deemed to have disposed of it for an amount equal to the lesser of the proceeds of disposition of the property and its capital cost. …

…[T]o the extent that the CFVP was the only depreciable property included in Class 10, the change in use of the CFVP results in no property being included in Class 10. If there is a positive UCC balance in the class after deducting the lesser of the proceeds of disposition of the CFVP and its capital cost, we are of the view that the corporation can claim a terminal loss on that balance.

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