23 May 1990 Income Tax Severed Letter AC74789 - Investment Tax Credit - Qualified Property

By services, 22 July, 2022
Official title
Investment Tax Credit - Qualified Property
Language
English
Document number
Citation name
AC74789
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
657991
Extra import data
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"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1990-05-23 08:00:00",
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Main text
K.K. Horton                         Head Office
Director                            Specialty Rulings Directorate
Sydney District Office              J.D. Brooks
                                    957-2097
M. Morrison
Subject: Investment Tax Credit
         Qualified Property

We are writing to you in response to your memorandum of March 6, 1990 in which you queried whether, in respect to vessels, the term "in Canada" as used in the definition of "qualified property" in subsection 127(9) of the Income Tax Act includes waters that are 12 to 200 miles off the coast of Canada.

We concur with your opinion that, based on the present wording of the Income Tax Act and Regulations, vessels used in these waters are not used in Canada and therefore do not qualify for investment tax credits. Pursuant to the definition of qualified property, the relevant consideration is the primary purpose for which an asset is acquired, and the vessels referred to apparently were not acquired to be used in Canada primarily for the purpose of fishing.

21(1)(a)

for Director Business and General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch