Words and Phrases - "ancillary"

a
88
b
44
c
80
d
54
e
38
f
31
g
20
h
14
i
74
j
2
k
2
l
32
m
56
n
25
o
38
p
81
q
3
r
77
s
90
t
47
u
16
v
9
w
23
y
2

2011 Ruling 2010-0376801R3 - FIT Program (solar): revenue,

Summary Under
Tax Topics - Income Tax Act - Section 122.1 - Subsection 122.1(1) - Real or Immovable Property - Paragraph (b)
solar power systems on rental properties used to sell electricity were “ancillary”

A REIT carries on its activities through a subsidiary LP. LP will participate in the Feed-in Tariff Program offered by the Ontario Power Authority pursuant to which it will install solar photovoltaic systems on its properties and sell the electricity generated at a guaranteed price per kWh. The total amount of electricity produced will not exceed the total level of electricity that will be consumed across all of the Ontario properties.

Ruling that the solar photovoltaic systems are property described in s. (b)(ii) of the definition of "real or immovable property".

Words and Phrases
ancillary