8 January 2008 Internal T.I. 2007-0254881I7 F - Amortissement d'une aire de camping -- summary under Class 1

Regarding the classification of a septic tank on a campground, the Directorate referred to Superior Pre-Kast Septic Tanks ([1978] 2 SCR 612), and stated:

[S]eptic tanks on a campground are "structures" for the purposes of the Act. Based on a reading of depreciation classes 1, 3, 6 and 8, we believe that such property should be included in either Class 1 or Class 3, depending on when it was acquired.

As for swimming pools that may be found at campgrounds, we are of the view that they are depreciable property included in Class 6(e) of Schedule II to the ITR. In this regard, we refer you to the decision in Amelia Podhorn v. Minister of National Revenue, 66 DTC 223 (T.A.B.) - which was based on Oriole Park Fairways Limited v. M.N.R. 56 DTC 537 (I.T.B.A.) - to conclude that a swimming pool in a hotel complex was a water storage tank for the purposes of Class 6(e).

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