14 September 2009 Internal T.I. 2009-0330871I7 - HRTC - Sandblasting of exterior brick

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HRTC - Sandblasting of exterior brick
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2009-0330871I7
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Principal Issues: Does the sandblasting of exterior brick on an eligible dwelling qualify as an eligible expenditure for the home renovation tax credit.

Position: Yes

Reasons: The sandblasting of the exterior brick on a building that is an eligible dwelling would be a "renovation" that is of an enduring nature and the brick is integral to the eligible dwelling. Furthermore, sandblasting exterior brick of an eligible dwelling is not an annual, recurring or routine repair or maintenance.

								September 14, 2009
	Individual Programs Section			HEADQUARTERS
	Taxpayer Services Directorate			Income Tax Rulings
			   					Directorate
	Attention to:  Sally Wilson			Andrea Boyle, CGA
								2009-033087

Home Renovation Tax Credit

This in reply to your email, dated July 6, 2009, regarding the eligibility of sandblasting of exterior brick on an eligible dwelling for the new home renovation tax credit (HRTC).

Our comments

The legislation regarding the new HRTC, which was introduced in the federal budget tabled on January 27, 2009, has not yet been made public. However, the Honourable James M. Flaherty, Minister of Finance, has publicly announced that expenditures will qualify if they relate to a renovation or an alteration of an eligible dwelling, including land that forms part of the eligible dwelling, and if the renovation or alteration is of an enduring nature and is integral to the eligible dwelling. Such expenditures will include the cost of labour and professional services, building materials, fixtures, equipment rentals, and permits.

In our opinion the sandblasting of the exterior brick on a building that is an eligible dwelling would be a "renovation" that is of an enduring nature and the brick is integral to the eligible dwelling. Furthermore, sandblasting exterior brick of an eligible dwelling is not an annual, recurring or routine repair or maintenance. Therefore, we are of the view that the cost of sandblasting the exterior brick of an eligible dwelling will qualify for the HRTC.

We trust that these comments will be of assistance.

Yours truly,

Louise J. Roy, CGA
Manager
For Acting Director
Ontario Corporate Tax Division
Income Tax Rulings Directorate
Legislative Policy and Regulatory Affairs Branch