| 24(1) | File No. 5-9687 |
| G. Thornley | |
| (613) 957-2101 |
Attention: 19(1)
June 1, 1990
Dear Sirs:
Re: Classification of Photocopier Equipment
This is in reply to your letter of February 12, 1990 with letter attached dated July 4, 1989 addressed to Assessing and Enquiries concerning the above noted subject to which we have been asked to reply.
In your view the evolution in photocopier equipment requires the reclassification of this type of equipment as "general purpose electronic data processing equipment" as defined in subsection 1104(2) of the Income Tax Regulations (the "Regulations"). Accordingly, in your view, this new generation of equipment should be more properly classified under Class 10 of the Regulations rather than under Class 8, as it now is.
As discussed with you during our telephone conversation of April 6, 1990 (19(1)/Thornley), the Department is not disposed to this view. In our opinion "general purpose electronic data processing equipment" in Regulation 1104(2) refers to computer equipment rather than a photocopier, notwithstanding that a photocopier may contain some components similar to those used in a computer.
We have discussed this matter with personnel from the Current Amendments Division who confirm our view that photocopier equipment is properly classified under Class 8 of Schedule 2 of the Regulations. They are also of the view that the Department of Finance does not intend to reclassify such equipment as Class 10 property for purposes of claiming capital cost allowances under paragraph 20(1)(a) of the Act.
We trust our comments will be of assistance to you in this matter.
Yours truly,
for DirectorBusiness and General DivisionSpecialty Rulings DirectorateLegislative and Intergovernmental Affairs Branch