Principal Issues: Whether the position expressed in Technical Interpretation 2013-0487791E5 represents the position of the Canada Revenue Agency.
Position: Yes.
XXXXXXXXXX 2021-091784
November 18, 2021
Dear Sir,
Subject: Tax treatment of income from emphyteusis
This letter is in response to your email of November 5, 2021 in which you asked whether the position set out in Technical Interpretation 2013-0487791E5 regarding the tax treatment of income derived from an emphyteusis represents the position of the Canada Revenue Agency.
We hereby confirm that the position set out in Technical Interpretation 2013-0487791E5 represents our position.
Best regards,
Isabelle Landry
Interim Manager
Business and Employment Income Division
Income Tax Rulings Directorate
Legislative Policy and Regulatory Affairs Branch