| 19(1) | File No. 5-8495 |
| J. Chan | |
| (613) 952-9019 |
November 1, 1989
Dear Sirs:
Re: Classification of Pipelines for CCA Purposes
We are writing in reply to your letter dated May 24, 1989, wherein, you requested confirmation that certain gas sales pipelines would qualify for class 8 treatment under Schedule II of the Income Tax Regulations (the "Regulations") by virtue of paragraph (i) thereof.
Your request is pursuant to class 2(b) of the Regulations which provided that a pipeline, other than gas or oil well equipment, will be included therein for capital cost allowance purposes, unless, in the case of oil or natural gas pipelines, the Minister in consultation with the Minister of Energy, Mines and Resources, is satisfied that the main source of supply for the pipeline is likely to be exhausted within 15 year from the date on which operation of the pipeline commenced. In the latter case, the pipeline may be included in Class 8 of the Regulations by virtue or paragraph (i) thereof.
At our request, the following opinion was provided by the Department of Energy, Mines and Resources 24(1)
We concur with the above opinion.
24(1)
Yours truly,
Section ChiefResource Industries SectionBilingual Services and ResourceIndustries DivisionRulings Directorate.