4 April 2005 External T.I. 2004-0099411E5 F - Transfert de contrat de crédit-bail -- summary under Subsection 49(1)

CRA noted its position that where a lease had a bargain purchase option, a portion of each lease payment was to be treated as allocable to consideration paid for the option and not as deductible rent, and then noted that if the lessee sold its interest in the lease agreement for an amount equaling the difference between the FMV of the property and the value of the future lease-payment obligations, such purchase price likely should be allocated to the embedded option.