| November 15, 1989 | |
| Mrs. L. Tremblay | Current Amendments and |
| Acting Director | Regulations Division |
| Appeals & Referrals Division | R.D. Weil/957-2066 |
| Appeals Branch | |
| Attention: Mr. D.W. Baines | File No. F-3386 |
Ontario Store Fixtures Inc. v. M.N.R. Adverse Decision - Tax Court of Canada Appeal Period Expires on January 23, 1990
This is to reply to your memorandum of October 31, 1989 concerning the reason behind the 1985 amendment to paragraph 18(1)(1) of the French version of the Act.
As indicated in the attached copies of correspondence, the substitution of the word "chalet-hôtel" for the work "chalet" was made as a result of the unreported 1984 decision of the Tax Court of Canada in the case of Guardian Inspection Services Ltd. v. M.N.R. The purpose of the amendment appears to have been to ensure that expenses for the use of a commercial lodge were not excluded from the scope of the provision because of the term "chalet" in the French version. From a review of our files and discussion with officials of the Department of Finance, there does not appear to have been any intention in making the French version amendment to alter the ordinary and everyday meaning of the term "lodge" in the English version.
If we can be of any further assistance to you in this matter, please contact us.
B.J. BrysonActing Director Current Amendments and Regulations Division
Attachment
RDW/jab