24 June 2024 External T.I. 2023-1000861E5 - Clean technology property and phase out of AIIP -- summary under Element A

The only Class 43.1 or 43.2 property transactions of the taxpayer were that it acquired (solar energy) equipment described in Class 43.1(d)(vi) in November 2024 (becoming available for use in January 2025) for $20M and acquired more such equipment in June 2027 (becoming available for use in July 2027) for $10M. The specified energy property rules did not apply because it met one of the exceptions in Reg.1100(25) or (26).

CRA noted that because the $20M of property was acquired before 2025, it would be a Class 43.2 property (50% CCA rate) rather than a Class 43.1 property (30% CCA rate) even though no CCA could be claimed until 2025 due to the available-for-use rules.

Its CCA claim for 2025 would be calculated as follows:

Capital cost $20M
AII per Reg. 1100(2) – A - (c)(ii) (i.e., 1/2 X $20M) $10M
Subtotal $30M
CCA (50% Class 43.2 rate) $15M

The “clean tech” ITC under s. 127.45(1) for 2027 would be 20% of the capital cost of $20M, or $4M.

CCA for 2026 would be $0.5M (i.e., the 50% CCA rate applied to the $20M capital cost as reduced by the $4M ITC claimed and the $15M CCA claim).

The CCA claim for 2027 would consist of a further $0.25M for the Class 43.2 property plus CCA regarding the $10M Class 43.1 acquisition calculated as follows:

Capital cost $10M
AII per Reg. 1100(2) – A - (b)(iii) (i.e., 5/6 X $10M) $8.33M
Subtotal $18.33M
CCA (30% Class 43.2 rate) $5.5M

The clean tech ITC for 2027 would be 20% of the capital cost of $10M, or $2M.

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