| 921842 | |
| L. Holloway | |
| (957-2131) | |
| June 30, 1992 |
Minister/DM's Office YS 92-4865TCentral RecordsAuthor/Section ChiefDistrict OfficeResearch FileTaxpayer's FileReturn to Rulings Directorate, Room 303, Met. signed by Pierre Gravelle on July 3, 1992
19(1)
Dear 19(1)
I am writing in response to your letter of May 15, 1992, which was forwarded by The Honourable Don Mazankowski, concerning the deductibility of mortgage interest costs incurred in financing your personal residence. I have reviewed the situation and can confirm that the information provided in the Department's previous letters to you of March 16, and 31, 1992, is correct. A building must be used in connection with the earning of business income or property income in order for mortgage interest expenditures to be deductible. If the building is not being used for income-earning purposes, as in the case of a personal residence for example, then expenditures incurred in connection with the property would not be deductible.
I regret that I am unable to be of further assistance to you in this matter.
Yours sincerely,
Pierre Gravelle, Q.C.