7 October 2011 Roundtable, 2011-0411811C6 F - Règlement 1101(5b.1) -- summary under Subsection 1101(5b.1)

A Inc. and B Inc. (with calendar year ends) are members of a partnership with a January 31 year end that acquired an eligible non-residential building. In finding that it is the partnership rather than A Inc. and B Inc. that is required to make the make the Reg. 1101(5b.1) election, CRA stated:

[W]here a partnership acquires an eligible non-residential building, the additional capital cost allowance provided for in ITR paragraphs 1100(1)(a.1) and (a.2) must be claimed at the partnership level. … Thus, the CRA considers that it is not possible to permit a member of a partnership to directly claim capital cost allowance for an eligible non-residential building, as this would be contrary to the rules respecting the computation of a partnership's income … .

… [W]hen a partnership files a T5013 for its fiscal year, it must attach a letter indicating the election under ITR subsection 1101(5b.1). Where all the conditions of ITR subsection 1101(5b.1) are satisfied, we confirm that an election made by a partner of a partnership is deemed to have been made by each partner of that partnership.

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