| 24(1) | 902690 |
| C. Tremblay | |
| 19(1) | (613) 952-1361 |
October 18, 1990
Dear Sirs:
Re: "Class 24 / Class 27"
This is in reply to your letter of September 18, 1990, requesting a copy of a recent technical interpretation dealing with the application of Classes 24 and 27 as described in schedule II of the Income Tax Regulations. Such a request can only be granted through the Access to Information Act: you should send your request to the Co-Ordinator, Access to Information with the appropriate fee at the address below. For your convenience we have included an Access to Information Request Form.
Room 502, 88 Metcalfe Street Ottawa, Ontario K1A 0L8
We are, however, prepared to provide some general comments with respect to whom the taxpayer must be to qualify for class 24 or 27 treatment. It is our opinion that, by implication, the use of the words "by him" in clause (b)(iii)(D) of class 24 and subparagraph (c)(iv) of class 27 refers to both the commencement of construction and the execution of an agreement in writing prior to 1974. This is consistent with the intent of the regulation, which was to ensure that these incentive provisions applied only to the original taxpayer. This is also consistent with the wording in clauses (b)(iii)(C) and (E) of class 24 and subparagraphs (c)(iii) and (v) of class 27 which require continual operation by the taxpayer from before 1974.
We trust that our comments will be of assistance to you.
Yours truly,
for DirectorBusiness and General DivisionSpecialty Rulings DirectorateLegislative and Intergovernmental Affairs Branch