CRA Again Confirms Subsection 45(1) Does Not Apply To A Conversion From Inventory To Depreciable Property
In 2015-0596921E5, CRA confirmed the view expressed in 2013-0493811C6 that the change-in-use rule in subsection 45(1) should apply only where the use of the property changes from a personal use to an income earning use (and vice versa) and should not apply where the property changes from inventory to depreciable property (and vice versa). The confirmation marks CRA’s continuing disagreement with the view of Federal Court of Appeal as stated in C.A.E. Inc. v. The Queen, 2013 FCA 92.