Hare v. Canada, 2013 DTC 5066 [at at 5868], 2013 FCA 80, aff'g 2011 DTC 1215 [at 1262], 2011 TCC 294 (Informal Procedure) -- summary under Improvements v. Repairs or Running Expense

By services, 28 November, 2015

Renovation costs incurred on a residential rental property, including new doors, windows and siding, were of a capital nature given that they were incurred before any tenant rented the property. Hershfield J reasoned (at TCC para. 59) that the expenses "strike me as having been incurred, foreseen or not, as part of the process of acquiring the properties." He suggested (at para. 66) that renovations are more likely to be on current account where they are "undertaken to make the property suitable for normal use again by the same owner."

In affirming Hershfield J's findings (principally by deferring to his findings of fact), Blais CJ noted he was correct in evaluating the series of repairs collectively, rather than item-by-item.

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