Précis: The taxpayer expended roughly $4 million over a period of two years replacing a large portion of the roof of an underground parking garage that had been damaged by salt. The taxpayer sought to deduct the expense as a current operating cost. The area involved was roughly 47,000 square feet which was about 50% of the size of the parking area; a sizeable portion of the remaining area was covered by three buildings and not exposed to the same damage. CRA denied the deduction as being a capital expenditure. The Tax Court accepted the position of the taxpayer and allowed the appeal with costs.
Aon Inc. v. R. - TCC: Replacing 50% of the roof of a parking garage ($4 million) a deductible expense.Plus >