19 April 2022 Internal T.I. 2020-0873571I7 - CERS Interest paid on a debt obligation as qualifying rent expense -- summary under Clause (b)(i)(B)

Is the s. 248(1) “cost amount” definition applicable to s. (b)(i)(B) of A of “qualifying rent expense,” and when should the cost amount be determined? After noting that this limitation (the “Cost Limit”) is determined in accordance with the s. 248(1) definition so that it generally would reference the ACB of non-depreciable property and the pro rata UCC of depreciable property, the Directorate went on to indicate:

As qualifying rent expense is determined in respect of a qualifying property for an eligible entity for a qualifying period, the cost amount of a qualifying property for purposes of the Cost Limit should also be determined in respect of a particular qualifying period. For example, the UCC of a depreciable property for a particular qualifying period would also be its Cost Limit.

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