20 November 1991 External T.I. 9121695 F - Capital Cost Allowance Deduction By A Partnership

By services, 18 January, 2022
Official title
Capital Cost Allowance Deduction By A Partnership
Language
French
CRA tags
96(1)(a)
Document number
Citation name
9121695
Severed letter type
Technical Interpretation - External
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
632836
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1991-11-20 07:00:00",
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Main text

5-912169

Dear Sirs:

Re: Capital Cost Allowance Deduction ("CCA") by a Partnership

This is in reply to your letter of July 31, 1991, wherein you asked if each partner was permitted to claim its own amount of CCA that pertains to its interest in property owned by the partnership.

Paragraph 96(1)(a) of the Act states that for purposes of calculating a partnership's taxable income it is to be treated as a separate person resident in Canada.  Thus the partnership owns depreciable capital property and for tax purposes must make any claim of capital cost allowance pertaining to such property.

We trust that our comments are of assistance.

Yours truly,

for DirectorManufacturing Industries, Partnerships and TrustsRulings Directorate    Legislative and Intergovernmental Affairs Branch