2 November 1989 Income Tax Severed Letter AC74259 - Appropriate CCA Clas for Ford Ranger Supercabs

Enquiries and Taxpayer                       J.D. Jones
 Assistance Division                         957-2104
P McNally
Director

Monica Jones - Kisil
                                             7-4259

SUBJECT:  Ford Ranger Supercabs
          Classification for Tax Purposes

This is in reply to your memorandum dated August 22, 1989, wherein you requested our opinion as to whether 1988 and 1989 Ford Ranger Supercab trucks are considered passenger vehicles for CCA purposes.

It is our understanding the 1988 and 1989 Ford Ranger Supercabs in question are pick-up trucks equipped with rear vinyl folding jump seats in the back of the cab and are used for business purposes. The taxpayer in question is asking whether the removal of the folding seats in the back would change the status of the truck such that the truck would not come within the definition of "automobile" as defined in subsection 248(1) of the Income Tax Act. It is also our view that the removal of the rear folding seats would not change this view unless their removal could be said to have permanently altered the vehicle such that the folding seats could not easily be refitted into the vehicle. The vehicle then may be said to be excluded from the definition of an "automobile" as it has been "adapted" to carry not more than the driver and 2 passengers.

                             21(1)(b)

B.W. Dath Director Business and General Division Specialty Rulings Directorate Legislative and Intergovernmental