← Historical versions

Versions of s. 66.2(5), definition “cumulative canadian development expense”

I-3.3 — Income Tax Act · 5 versions · View current text

Historical text comes from the Justice Laws point-in-time corpus and is unofficial — not the official version.

  1. 2026-03-26 to present available View Source
    cumulative Canadian development expense of a taxpayer at any time in a taxation year means the amount determined by the formula(A+B+C+D+D.1) - (E+F+G+H+I+J+K+L+M+M.1+N+O) where A is the total of all Canadian development expenses made or incurred by the taxpayer before that time, B is the total of all amounts that were, because of subsection (1), included in computing the amount referred to in paragraph 59(3.2)(c) for taxation years ending before that time, C is the total of all amounts referred to in the description of F or G that are established by the taxpayer to have become bad debts before that time, D is such part, if any, of the amount determined for M as has been repaid before that time by the taxpayer pursuant to a legal obligation to repay all or any part of that amount, D.1 is the total of all specified amounts, determined under paragraph 66.7(12.1)(b) in respect of the taxpayer for taxation years ending before that time, E is the total of all amounts deducted in computing the taxpayer’s income for a taxation year ending before that time in respect of the taxpayer’s cumulative Canadian development expense, F is the total of all amounts each of which is an amount in respect of property described in paragraph (b), (e) or (f) of the definition Canadian resource property in subsection 66(15) or property disposed of after March 21, 2011 which was described in any of those paragraphs and the cost of which when acquired by the taxpayer was included in the Canadian development expense of the taxpayer, or any right to or interest in — or, for civil law, any right in or to — such a property, other than such a right or an interest that the taxpayer has by reason of being a beneficiary under a trust or a member of a partnership, (in this description referred to as “the particular property”) disposed of by the taxpayer before that time equal to the amount, if any, by which the amount, if any, by which the proceeds of disposition in respect of the particular property that became receivable by the taxpayer after May 6, 1974 and before that time exceed any outlays or expenses that were made or incurred by the taxpayer after May 6, 1974 and before that time for the purpose of making the disposition and that were not otherwise deductible for the purposes of this Part exceeds the amount, if any, by which the total of all amounts that would be determined under paragraph 66.7(4)(a), immediately before the time (in this paragraph referred to as the “relevant time”) when such proceeds of disposition became receivable, in respect of the taxpayer and an original owner of the particular property (or of any other property acquired by the taxpayer with the particular property in circumstances in which subsection 66.7(4) applied and in respect of which the proceeds of disposition became receivable by the taxpayer at the relevant time) if amounts that became receivable at or after the relevant time were not taken into account, each designation made under subparagraph 66.7(4)(a)(iii) in respect of an amount that became receivable before the relevant time were made before the relevant time, paragraph 66.7(4)(a) were read without reference to “30% of”, and no reduction under subsection 80(8) at or after the relevant time were taken into account exceeds the total of all amounts that would be determined under paragraph 66.7(4)(a) at the relevant time in respect of the taxpayer and an original owner of the particular property (or of that other property) if amounts that became receivable after the relevant time were not taken into account, each designation made under subparagraph 66.7(4)(a)(iii) in respect of an amount that became receivable at or before the relevant time were made before the relevant time, paragraph 66.7(4)(a) were read without reference to “30% of”, amounts described in subparagraph 66.7(4)(a)(iii) that became receivable at the relevant time were not taken into account, and no reduction under subsection 80(8) at or after the relevant time were taken into account, and such portion of the amount otherwise determined under this paragraph as was otherwise applied to reduce the amount otherwise determined under this description, G is the total of all amounts that became receivable by the taxpayer before that time that are to be included in the amount determined under this description by virtue of paragraph 66(12.1)(b) or 66(12.3)(a), H is the total of all amounts each of which is an amount included by the taxpayer as an expense under paragraph (a) of the definition Canadian development expense in this subsection in computing the taxpayer’s Canadian development expense for a previous taxation year that has become a Canadian exploration expense of the taxpayer by virtue of subparagraph (c)(ii) of the definition Canadian exploration expense in subsection 66.1(6), I is the total of all amounts each of which is an amount that before that time has become a Canadian exploration expense of the taxpayer by virtue of subsection 66.1(9), J is the total of all amounts each of which is an amount received before that time on account of any amount referred to in the description of C K is the total of all amounts paid to the taxpayer after May 6, 1974 and before May 25, 1976 under the Northern Mineral Exploration Assistance Regulations made under an appropriation Act that provides for payments in respect of the Northern Mineral Grants Program, or pursuant to any agreement, entered into between the taxpayer and Her Majesty in right of Canada under the Northern Mineral Grants Program or the Development Program of the Department of Indian Affairs and Northern Development, to the extent that the amounts have been expended by the taxpayer as or on account of Canadian development expense incurred by the taxpayer, L is the amount by which the total of all amounts determined under subsection 66.4(1) in respect of a taxation year of the taxpayer ending at or before that time exceeds the total of all amounts each of which is the least of the amount that would be determined under paragraph 66.7(4)(a), at a time (hereafter in this description referred to only as the “particular time”) that is the end of the latest taxation year of the taxpayer ending at or before that time, in respect of the taxpayer as successor in respect of a disposition (in this description referred to as the “original disposition”) of Canadian resource property by a person who is an original owner of the property because of the original disposition, if that paragraph were read without reference to “30% of”, where the taxpayer has disposed of all or part of the property in circumstances in which subsection 66.7(4) applied, that subsection continued to apply to the taxpayer in respect of the original disposition as if subsequent successors were the same person as the taxpayer, and each designation made under subparagraph 66.7(4)(a)(iii) in respect of an amount that became receivable before the particular time were made before the particular time, the amount, if any, by which the total of all amounts each of which became receivable at or before the particular time and before 1993 by the taxpayer and is included in computing the amount determined under subparagraph 66.7(5)(a)(ii) in respect of the original disposition exceeds the amount, if any, by which where the taxpayer disposed of all or part of the property before the particular time in circumstances in which subsection 66.7(5) applied, the amount that would be determined at the particular time under subparagraph 66.7(5)(a)(i) in respect of the original disposition if that subparagraph continued to apply to the taxpayer in respect of the original disposition as if subsequent successors were the same person as the taxpayer, and in any other case, the amount determined at the particular time under subparagraph 66.7(5)(a)(i) in respect of the original disposition exceeds the amount that would be determined at the particular time under subparagraph 66.7(5)(a)(ii) in respect of the original disposition if that subparagraph were read without reference to the words “or the successor”, wherever they appear therein, and if amounts that became receivable after 1992 were not taken into account, and where after the original disposition and at or before the particular time, the taxpayer disposed of all or part of the property in circumstances in which subsection 66.7(4) applied, otherwise than by way of an amalgamation or merger or solely because of the application of paragraph 66.7(10)(c), and the winding-up of the taxpayer began at or before that time or the taxpayer’s disposition referred to in subparagraph (i) (other than a disposition under an agreement in writing entered into before December 22, 1992) occurred after December 21, 1992, nil M is the total amount of assistance that the taxpayer has received or is entitled to receive in respect of any Canadian development expense (including an expense that has become a Canadian exploration expense of the taxpayer by virtue of subsection 66.1(9)) incurred after 1980 or that can reasonably be related to Canadian development activities after 1980, M.1 is the total of all amounts by which the cumulative Canadian development expense of the taxpayer is required because of subsection 80(8) to be reduced at or before that time, N is the total of all amounts that are required to be deducted before that time under subsection 66(14.2) in computing the taxpayer’s cumulative Canadian development expense, and O is the total of all amounts that are required to be deducted before that time under paragraph 66.7(12)(c) in computing the taxpayer’s cumulative Canadian development expense.expense; (frais cumulatifs d’aménagement au Canada)
    Full text

    cumulative Canadian development expense of a taxpayer at any time in a taxation year means the amount determined by the formula(A+B+C+D+D.1) - (E+F+G+H+I+J+K+L+M+M.1+N+O) where A is the total of all Canadian development expenses made or incurred by the taxpayer before that time, B is the total of all amounts that were, because of subsection (1), included in computing the amount referred to in paragraph 59(3.2)(c) for taxation years ending before that time, C is the total of all amounts referred to in the description of F or G that are established by the taxpayer to have become bad debts before that time, D is such part, if any, of the amount determined for M as has been repaid before that time by the taxpayer pursuant to a legal obligation to repay all or any part of that amount, D.1 is the total of all specified amounts, determined under paragraph 66.7(12.1)(b) in respect of the taxpayer for taxation years ending before that time, E is the total of all amounts deducted in computing the taxpayer’s income for a taxation year ending before that time in respect of the taxpayer’s cumulative Canadian development expense, F is the total of all amounts each of which is an amount in respect of property described in paragraph (b), (e) or (f) of the definition Canadian resource property in subsection 66(15) or property disposed of after March 21, 2011 which was described in any of those paragraphs and the cost of which when acquired by the taxpayer was included in the Canadian development expense of the taxpayer, or any right to or interest in — or, for civil law, any right in or to — such a property, other than such a right or an interest that the taxpayer has by reason of being a beneficiary under a trust or a member of a partnership, (in this description referred to as “the particular property”) disposed of by the taxpayer before that time equal to the amount, if any, by which the amount, if any, by which the proceeds of disposition in respect of the particular property that became receivable by the taxpayer after May 6, 1974 and before that time exceed any outlays or expenses that were made or incurred by the taxpayer after May 6, 1974 and before that time for the purpose of making the disposition and that were not otherwise deductible for the purposes of this Part exceeds the amount, if any, by which the total of all amounts that would be determined under paragraph 66.7(4)(a), immediately before the time (in this paragraph referred to as the “relevant time”) when such proceeds of disposition became receivable, in respect of the taxpayer and an original owner of the particular property (or of any other property acquired by the taxpayer with the particular property in circumstances in which subsection 66.7(4) applied and in respect of which the proceeds of disposition became receivable by the taxpayer at the relevant time) if amounts that became receivable at or after the relevant time were not taken into account, each designation made under subparagraph 66.7(4)(a)(iii) in respect of an amount that became receivable before the relevant time were made before the relevant time, paragraph 66.7(4)(a) were read without reference to “30% of”, and no reduction under subsection 80(8) at or after the relevant time were taken into account exceeds the total of all amounts that would be determined under paragraph 66.7(4)(a) at the relevant time in respect of the taxpayer and an original owner of the particular property (or of that other property) if amounts that became receivable after the relevant time were not taken into account, each designation made under subparagraph 66.7(4)(a)(iii) in respect of an amount that became receivable at or before the relevant time were made before the relevant time, paragraph 66.7(4)(a) were read without reference to “30% of”, amounts described in subparagraph 66.7(4)(a)(iii) that became receivable at the relevant time were not taken into account, and no reduction under subsection 80(8) at or after the relevant time were taken into account, and such portion of the amount otherwise determined under this paragraph as was otherwise applied to reduce the amount otherwise determined under this description, G is the total of all amounts that became receivable by the taxpayer before that time that are to be included in the amount determined under this description by virtue of paragraph 66(12.1)(b) or 66(12.3)(a), H is the total of all amounts each of which is an amount included by the taxpayer as an expense under paragraph (a) of the definition Canadian development expense in this subsection in computing the taxpayer’s Canadian development expense for a previous taxation year that has become a Canadian exploration expense of the taxpayer by virtue of subparagraph (c)(ii) of the definition Canadian exploration expense in subsection 66.1(6), I is the total of all amounts each of which is an amount that before that time has become a Canadian exploration expense of the taxpayer by virtue of subsection 66.1(9), J is the total of all amounts each of which is an amount received before that time on account of any amount referred to in the description of C K is the total of all amounts paid to the taxpayer after May 6, 1974 and before May 25, 1976 under the Northern Mineral Exploration Assistance Regulations made under an appropriation Act that provides for payments in respect of the Northern Mineral Grants Program, or pursuant to any agreement, entered into between the taxpayer and Her Majesty in right of Canada under the Northern Mineral Grants Program or the Development Program of the Department of Indian Affairs and Northern Development, to the extent that the amounts have been expended by the taxpayer as or on account of Canadian development expense incurred by the taxpayer, L is the amount by which the total of all amounts determined under subsection 66.4(1) in respect of a taxation year of the taxpayer ending at or before that time exceeds the total of all amounts each of which is the least of the amount that would be determined under paragraph 66.7(4)(a), at a time (hereafter in this description referred to only as the “particular time”) that is the end of the latest taxation year of the taxpayer ending at or before that time, in respect of the taxpayer as successor in respect of a disposition (in this description referred to as the “original disposition”) of Canadian resource property by a person who is an original owner of the property because of the original disposition, if that paragraph were read without reference to “30% of”, where the taxpayer has disposed of all or part of the property in circumstances in which subsection 66.7(4) applied, that subsection continued to apply to the taxpayer in respect of the original disposition as if subsequent successors were the same person as the taxpayer, and each designation made under subparagraph 66.7(4)(a)(iii) in respect of an amount that became receivable before the particular time were made before the particular time, the amount, if any, by which the total of all amounts each of which became receivable at or before the particular time and before 1993 by the taxpayer and is included in computing the amount determined under subparagraph 66.7(5)(a)(ii) in respect of the original disposition exceeds the amount, if any, by which where the taxpayer disposed of all or part of the property before the particular time in circumstances in which subsection 66.7(5) applied, the amount that would be determined at the particular time under subparagraph 66.7(5)(a)(i) in respect of the original disposition if that subparagraph continued to apply to the taxpayer in respect of the original disposition as if subsequent successors were the same person as the taxpayer, and in any other case, the amount determined at the particular time under subparagraph 66.7(5)(a)(i) in respect of the original disposition exceeds the amount that would be determined at the particular time under subparagraph 66.7(5)(a)(ii) in respect of the original disposition if that subparagraph were read without reference to the words “or the successor”, wherever they appear therein, and if amounts that became receivable after 1992 were not taken into account, and where after the original disposition and at or before the particular time, the taxpayer disposed of all or part of the property in circumstances in which subsection 66.7(4) applied, otherwise than by way of an amalgamation or merger or solely because of the application of paragraph 66.7(10)(c), and the winding-up of the taxpayer began at or before that time or the taxpayer’s disposition referred to in subparagraph (i) (other than a disposition under an agreement in writing entered into before December 22, 1992) occurred after December 21, 1992, nil M is the total amount of assistance that the taxpayer has received or is entitled to receive in respect of any Canadian development expense (including an expense that has become a Canadian exploration expense of the taxpayer by virtue of subsection 66.1(9)) incurred after 1980 or that can reasonably be related to Canadian development activities after 1980, M.1 is the total of all amounts by which the cumulative Canadian development expense of the taxpayer is required because of subsection 80(8) to be reduced at or before that time, N is the total of all amounts that are required to be deducted before that time under subsection 66(14.2) in computing the taxpayer’s cumulative Canadian development expense, and O is the total of all amounts that are required to be deducted before that time under paragraph 66.7(12)(c) in computing the taxpayer’s cumulative Canadian development expense; (frais cumulatifs d’aménagement au Canada)

  2. 2013-12-12 to 2026-03-26 View Source
    cumulative Canadian development expense of a taxpayer at any time in a taxation year means the amount determined by the formula(A+B+C+D+D.1) - (E+F+G+H+I+J+K+L+M+M.1+N+O) where A is the total of all Canadian development expenses made or incurred by the taxpayer before that time, B is the total of all amounts that were, because of subsection (1), included in computing the amount referred to in paragraph 59(3.2)(c) for taxation years ending before that time, C is the total of all amounts referred to in the description of F or G that are established by the taxpayer to have become bad debts before that time, D is such part, if any, of the amount determined for M as has been repaid before that time by the taxpayer pursuant to a legal obligation to repay all or any part of that amount, D.1 is the total of all specified amounts, determined under paragraph 66.7(12.1)(b) in respect of the taxpayer for taxation years ending before that time, E is the total of all amounts deducted in computing the taxpayer’s income for a taxation year ending before that time in respect of the taxpayer’s cumulative Canadian development expense, F is the total of all amounts each of which is an amount in respect of property described in paragraph (b), (e) or (f) of the definition Canadian resource property in subsection 66(15) or property disposed of after March 21, 2011 which was described in any of those paragraphs and the cost of which when acquired by the taxpayer was included in the Canadian development expense of the taxpayer, or any right to or interest in — or, for civil law, any right in or to — such a property, other than such a right or an interest that the taxpayer has by reason of being a beneficiary under a trust or a member of a partnership, (in this description referred to as “the particular property”) disposed of by the taxpayer before that time equal to the amount, if any, by which the amount, if any, by which the proceeds of disposition in respect of the particular property that became receivable by the taxpayer after May 6, 1974 and before that time exceed any outlays or expenses that were made or incurred by the taxpayer after May 6, 1974 and before that time for the purpose of making the disposition and that were not otherwise deductible for the purposes of this Part exceeds the amount, if any, by which the total of all amounts that would be determined under paragraph 66.7(4)(a), immediately before the time (in this paragraph referred to as the “relevant time”) when such proceeds of disposition became receivable, in respect of the taxpayer and an original owner of the particular property (or of any other property acquired by the taxpayer with the particular property in circumstances in which subsection 66.7(4) applied and in respect of which the proceeds of disposition became receivable by the taxpayer at the relevant time) if amounts that became receivable at or after the relevant time were not taken into account, each designation made under subparagraph 66.7(4)(a)(iii) in respect of an amount that became receivable before the relevant time were made before the relevant time, paragraph 66.7(4)(a) were read without reference to “30% of”, and no reduction under subsection 80(8) at or after the relevant time were taken into account exceeds the total of all amounts that would be determined under paragraph 66.7(4)(a) at the relevant time in respect of the taxpayer and an original owner of the particular property (or of that other property) if amounts that became receivable after the relevant time were not taken into account, each designation made under subparagraph 66.7(4)(a)(iii) in respect of an amount that became receivable at or before the relevant time were made before the relevant time, paragraph 66.7(4)(a) were read without reference to “30% of”, amounts described in subparagraph 66.7(4)(a)(iii) that became receivable at the relevant time were not taken into account, and no reduction under subsection 80(8) at or after the relevant time were taken into account, and such portion of the amount otherwise determined under this paragraph as was otherwise applied to reduce the amount otherwise determined under this description, G is the total of all amounts that became receivable by the taxpayer before that time that are to be included in the amount determined under this description by virtue of paragraph 66(12.1)(b) or 66(12.3)(a), H is the total of all amounts each of which is an amount included by the taxpayer as an expense under paragraph (a) of the definition Canadian development expense in this subsection in computing the taxpayer’s Canadian development expense for a previous taxation year that has become a Canadian exploration expense of the taxpayer by virtue of subparagraph (c)(ii) of the definition Canadian exploration expense in subsection 66.1(6), I is the total of all amounts each of which is an amount that before that time has become a Canadian exploration expense of the taxpayer by virtue of subsection 66.1(9), J is the total of all amounts each of which is an amount received before that time on account of any amount referred to in the description of C K is the total of all amounts paid to the taxpayer after May 6, 1974 and before May 25, 1976 under the Northern Mineral Exploration Assistance Regulations made under an appropriation Act that provides for payments in respect of the Northern Mineral Grants Program, or pursuant to any agreement, entered into between the taxpayer and Her Majesty in right of Canada under the Northern Mineral Grants Program or the Development Program of the Department of Indian Affairs and Northern Development, to the extent that the amounts have been expended by the taxpayer as or on account of Canadian development expense incurred by the taxpayer, L is the amount by which the total of all amounts determined under subsection 66.4(1) in respect of a taxation year of the taxpayer ending at or before that time exceeds the total of all amounts each of which is the least of the amount that would be determined under paragraph 66.7(4)(a), at a time (hereafter in this description referred to only as the “particular time”) that is the end of the latest taxation year of the taxpayer ending at or before that time, in respect of the taxpayer as successor in respect of a disposition (in this description referred to as the “original disposition”) of Canadian resource property by a person who is an original owner of the property because of the original disposition, if that paragraph were read without reference to “30% of”, where the taxpayer has disposed of all or part of the property in circumstances in which subsection 66.7(4) applied, that subsection continued to apply to the taxpayer in respect of the original disposition as if subsequent successors were the same person as the taxpayer, and each designation made under subparagraph 66.7(4)(a)(iii) in respect of an amount that became receivable before the particular time were made before the particular time, the amount, if any, by which the total of all amounts each of which became receivable at or before the particular time and before 1993 by the taxpayer and is included in computing the amount determined under subparagraph 66.7(5)(a)(ii) in respect of the original disposition exceeds the amount, if any, by which where the taxpayer disposed of all or part of the property before the particular time in circumstances in which subsection 66.7(5) applied, the amount that would be determined at the particular time under subparagraph 66.7(5)(a)(i) in respect of the original disposition if that subparagraph continued to apply to the taxpayer in respect of the original disposition as if subsequent successors were the same person as the taxpayer, and in any other case, the amount determined at the particular time under subparagraph 66.7(5)(a)(i) in respect of the original disposition exceeds the amount that would be determined at the particular time under subparagraph 66.7(5)(a)(ii) in respect of the original disposition if that subparagraph were read without reference to the words “or the successor”, wherever they appear therein, and if amounts that became receivable after 1992 were not taken into account, and where after the original disposition and at or before the particular time, the taxpayer disposed of all or part of the property in circumstances in which subsection 66.7(4) applied, otherwise than by way of an amalgamation or merger or solely because of the application of paragraph 66.7(10)(c), and the winding-up of the taxpayer began at or before that time or the taxpayer’s disposition referred to in subparagraph (i) (other than a disposition under an agreement in writing entered into before December 22, 1992) occurred after December 21, 1992, nil M is the total amount of assistance that the taxpayer has received or is entitled to receive in respect of any Canadian development expense (including an expense that has become a Canadian exploration expense of the taxpayer by virtue of subsection 66.1(9)) incurred after 1980 or that can reasonably be related to Canadian development activities after 1980, M.1 is the total of all amounts by which the cumulative Canadian development expense of the taxpayer is required because of subsection 80(8) to be reduced at or before that time, N is the total of all amounts that are required to be deducted before that time under subsection 66(14.2) in computing the taxpayer’s cumulative Canadian development expense, and O is the total of all amounts that are required to be deducted before that time under paragraph 66.7(12)(c) in computing the taxpayer’s cumulative Canadian development expense. (frais cumulatifs d’aménagement au Canada)
    Full text

    cumulative Canadian development expense of a taxpayer at any time in a taxation year means the amount determined by the formula(A+B+C+D+D.1) - (E+F+G+H+I+J+K+L+M+M.1+N+O) where A is the total of all Canadian development expenses made or incurred by the taxpayer before that time, B is the total of all amounts that were, because of subsection (1), included in computing the amount referred to in paragraph 59(3.2)(c) for taxation years ending before that time, C is the total of all amounts referred to in the description of F or G that are established by the taxpayer to have become bad debts before that time, D is such part, if any, of the amount determined for M as has been repaid before that time by the taxpayer pursuant to a legal obligation to repay all or any part of that amount, D.1 is the total of all specified amounts, determined under paragraph 66.7(12.1)(b) in respect of the taxpayer for taxation years ending before that time, E is the total of all amounts deducted in computing the taxpayer’s income for a taxation year ending before that time in respect of the taxpayer’s cumulative Canadian development expense, F is the total of all amounts each of which is an amount in respect of property described in paragraph (b), (e) or (f) of the definition Canadian resource property in subsection 66(15) or property disposed of after March 21, 2011 which was described in any of those paragraphs and the cost of which when acquired by the taxpayer was included in the Canadian development expense of the taxpayer, or any right to or interest in — or, for civil law, any right in or to — such a property, other than such a right or an interest that the taxpayer has by reason of being a beneficiary under a trust or a member of a partnership, (in this description referred to as “the particular property”) disposed of by the taxpayer before that time equal to the amount, if any, by which the amount, if any, by which the proceeds of disposition in respect of the particular property that became receivable by the taxpayer after May 6, 1974 and before that time exceed any outlays or expenses that were made or incurred by the taxpayer after May 6, 1974 and before that time for the purpose of making the disposition and that were not otherwise deductible for the purposes of this Part exceeds the amount, if any, by which the total of all amounts that would be determined under paragraph 66.7(4)(a), immediately before the time (in this paragraph referred to as the “relevant time”) when such proceeds of disposition became receivable, in respect of the taxpayer and an original owner of the particular property (or of any other property acquired by the taxpayer with the particular property in circumstances in which subsection 66.7(4) applied and in respect of which the proceeds of disposition became receivable by the taxpayer at the relevant time) if amounts that became receivable at or after the relevant time were not taken into account, each designation made under subparagraph 66.7(4)(a)(iii) in respect of an amount that became receivable before the relevant time were made before the relevant time, paragraph 66.7(4)(a) were read without reference to “30% of”, and no reduction under subsection 80(8) at or after the relevant time were taken into account exceeds the total of all amounts that would be determined under paragraph 66.7(4)(a) at the relevant time in respect of the taxpayer and an original owner of the particular property (or of that other property) if amounts that became receivable after the relevant time were not taken into account, each designation made under subparagraph 66.7(4)(a)(iii) in respect of an amount that became receivable at or before the relevant time were made before the relevant time, paragraph 66.7(4)(a) were read without reference to “30% of”, amounts described in subparagraph 66.7(4)(a)(iii) that became receivable at the relevant time were not taken into account, and no reduction under subsection 80(8) at or after the relevant time were taken into account, and such portion of the amount otherwise determined under this paragraph as was otherwise applied to reduce the amount otherwise determined under this description, G is the total of all amounts that became receivable by the taxpayer before that time that are to be included in the amount determined under this description by virtue of paragraph 66(12.1)(b) or 66(12.3)(a), H is the total of all amounts each of which is an amount included by the taxpayer as an expense under paragraph (a) of the definition Canadian development expense in this subsection in computing the taxpayer’s Canadian development expense for a previous taxation year that has become a Canadian exploration expense of the taxpayer by virtue of subparagraph (c)(ii) of the definition Canadian exploration expense in subsection 66.1(6), I is the total of all amounts each of which is an amount that before that time has become a Canadian exploration expense of the taxpayer by virtue of subsection 66.1(9), J is the total of all amounts each of which is an amount received before that time on account of any amount referred to in the description of C K is the total of all amounts paid to the taxpayer after May 6, 1974 and before May 25, 1976 under the Northern Mineral Exploration Assistance Regulations made under an appropriation Act that provides for payments in respect of the Northern Mineral Grants Program, or pursuant to any agreement, entered into between the taxpayer and Her Majesty in right of Canada under the Northern Mineral Grants Program or the Development Program of the Department of Indian Affairs and Northern Development, to the extent that the amounts have been expended by the taxpayer as or on account of Canadian development expense incurred by the taxpayer, L is the amount by which the total of all amounts determined under subsection 66.4(1) in respect of a taxation year of the taxpayer ending at or before that time exceeds the total of all amounts each of which is the least of the amount that would be determined under paragraph 66.7(4)(a), at a time (hereafter in this description referred to only as the “particular time”) that is the end of the latest taxation year of the taxpayer ending at or before that time, in respect of the taxpayer as successor in respect of a disposition (in this description referred to as the “original disposition”) of Canadian resource property by a person who is an original owner of the property because of the original disposition, if that paragraph were read without reference to “30% of”, where the taxpayer has disposed of all or part of the property in circumstances in which subsection 66.7(4) applied, that subsection continued to apply to the taxpayer in respect of the original disposition as if subsequent successors were the same person as the taxpayer, and each designation made under subparagraph 66.7(4)(a)(iii) in respect of an amount that became receivable before the particular time were made before the particular time, the amount, if any, by which the total of all amounts each of which became receivable at or before the particular time and before 1993 by the taxpayer and is included in computing the amount determined under subparagraph 66.7(5)(a)(ii) in respect of the original disposition exceeds the amount, if any, by which where the taxpayer disposed of all or part of the property before the particular time in circumstances in which subsection 66.7(5) applied, the amount that would be determined at the particular time under subparagraph 66.7(5)(a)(i) in respect of the original disposition if that subparagraph continued to apply to the taxpayer in respect of the original disposition as if subsequent successors were the same person as the taxpayer, and in any other case, the amount determined at the particular time under subparagraph 66.7(5)(a)(i) in respect of the original disposition exceeds the amount that would be determined at the particular time under subparagraph 66.7(5)(a)(ii) in respect of the original disposition if that subparagraph were read without reference to the words “or the successor”, wherever they appear therein, and if amounts that became receivable after 1992 were not taken into account, and where after the original disposition and at or before the particular time, the taxpayer disposed of all or part of the property in circumstances in which subsection 66.7(4) applied, otherwise than by way of an amalgamation or merger or solely because of the application of paragraph 66.7(10)(c), and the winding-up of the taxpayer began at or before that time or the taxpayer’s disposition referred to in subparagraph (i) (other than a disposition under an agreement in writing entered into before December 22, 1992) occurred after December 21, 1992, nil M is the total amount of assistance that the taxpayer has received or is entitled to receive in respect of any Canadian development expense (including an expense that has become a Canadian exploration expense of the taxpayer by virtue of subsection 66.1(9)) incurred after 1980 or that can reasonably be related to Canadian development activities after 1980, M.1 is the total of all amounts by which the cumulative Canadian development expense of the taxpayer is required because of subsection 80(8) to be reduced at or before that time, N is the total of all amounts that are required to be deducted before that time under subsection 66(14.2) in computing the taxpayer’s cumulative Canadian development expense, and O is the total of all amounts that are required to be deducted before that time under paragraph 66.7(12)(c) in computing the taxpayer’s cumulative Canadian development expense. (frais cumulatifs d’aménagement au Canada)

  3. 2013-06-26 to 2013-12-12 View Source
    cumulative Canadian development expense of a taxpayer at any time in a taxation year means the amount determined by the formula(A+B+C+D+D.1) - (E+F+G+H+I+J+K+L+M+M.1+N+O) where A is the total of all Canadian development expenses made or incurred by the taxpayer before that time, B is the total of all amounts requiredthat bywere, virtuebecause of subsection 66.2(1) to be(1), included in computing the amount referred to in paragraph 59(3.2)(c) for taxation years ending before that time, C is the total of all amounts referred to in the description of F or G that are established by the taxpayer to have become bad debts before that time, D is such part, if any, of the amount determined for M as has been repaid before that time by the taxpayer pursuant to a legal obligation to repay all or any part of that amount, D.1 is the total of all specified amounts, determined under paragraph 66.7(12.1)(b) in respect of the taxpayer for taxation years ending before that time, E is the total of all amounts deducted in computing the taxpayer’s income for a taxation year ending before that time in respect of the taxpayer’s cumulative Canadian development expense, F is the total of all amounts each of which is an amount in respect of property described in paragraph (b), (e) or (f) of the definition Canadian resource property in subsection 66(15) or property disposed of after March 21, 2011 which was described in any of those paragraphs and the cost of which when acquired by the taxpayer was included in the Canadian development expense of the taxpayer, or any right to or interest in — or, for civil law, any right in or to — such a property, other than such a right or an interest that the taxpayer has by reason of being a beneficiary under a trust or a member of a partnership, (in this description referred to as “the particular property”) disposed of by the taxpayer before that time equal to the amount, if any, by which the amount, if any, by which the proceeds of disposition in respect of the particular property that became receivable by the taxpayer after May 6, 1974 and before that time exceed any outlays or expenses that were made or incurred by the taxpayer after May 6, 1974 and before that time for the purpose of making the disposition and that were not otherwise deductible for the purposes of this Part exceeds the amount, if any, by which the total of all amounts that would be determined under paragraph 66.7(4)(a), immediately before the time (in this paragraph referred to as the “relevant time”) when such proceeds of disposition became receivable, in respect of the taxpayer and an original owner of the particular property (or of any other property acquired by the taxpayer with the particular property in circumstances in which subsection 66.7(4) applied and in respect of which the proceeds of disposition became receivable by the taxpayer at the relevant time) if amounts that became receivable at or after the relevant time were not taken into account, each designation made under subparagraph 66.7(4)(a)(iii) in respect of an amount that became receivable before the relevant time were made before the relevant time, paragraph 66.7(4)(a) were read without reference to “30% of”, and no reduction under subsection 80(8) at or after the relevant time were taken into account exceeds the total of all amounts that would be determined under paragraph 66.7(4)(a) at the relevant time in respect of the taxpayer and an original owner of the particular property (or of that other property) if amounts that became receivable after the relevant time were not taken into account, each designation made under subparagraph 66.7(4)(a)(iii) in respect of an amount that became receivable at or before the relevant time were made before the relevant time, paragraph 66.7(4)(a) were read without reference to “30% of”, amounts described in subparagraph 66.7(4)(a)(iii) that became receivable at the relevant time were not taken into account, and no reduction under subsection 80(8) at or after the relevant time were taken into account, and such portion of the amount otherwise determined under this paragraph as was otherwise applied to reduce the amount otherwise determined under this description, G is the total of all amounts that became receivable by the taxpayer before that time that are to be included in the amount determined under this description by virtue of paragraph 66(12.1)(b) or 66(12.3)(a), H is the total of all amounts each of which is an amount included by the taxpayer as an expense under paragraph (a) of the definition Canadian development expense in this subsection in computing the taxpayer’s Canadian development expense for a previous taxation year that has become a Canadian exploration expense of the taxpayer by virtue of subparagraph (c)(ii) of the definition Canadian exploration expense in subsection 66.1(6), I is the total of all amounts each of which is an amount that before that time has become a Canadian exploration expense of the taxpayer by virtue of subsection 66.1(9), J is the total of all amounts each of which is an amount received before that time on account of any amount referred to in the description of C K is the total of all amounts paid to the taxpayer after May 6, 1974 and before May 25, 1976 under the Northern Mineral Exploration Assistance Regulations made under an appropriation Act that provides for payments in respect of the Northern Mineral Grants Program, or pursuant to any agreement, entered into between the taxpayer and Her Majesty in right of Canada under the Northern Mineral Grants Program or the Development Program of the Department of Indian Affairs and Northern Development, to the extent that the amounts have been expended by the taxpayer as or on account of Canadian development expense incurred by the taxpayer, L is the amount by which the total of all amounts determined under subsection 66.4(1) in respect of a taxation year of the taxpayer ending at or before that time exceeds the total of all amounts each of which is the least of the amount that would be determined under paragraph 66.7(4)(a), at a time (hereafter in this description referred to only as the “particular time”) that is the end of the latest taxation year of the taxpayer ending at or before that time, in respect of the taxpayer as successor in respect of a disposition (in this description referred to as the “original disposition”) of Canadian resource property by a person who is an original owner of the property because of the original disposition, if that paragraph were read without reference to “30% of”, where the taxpayer has disposed of all or part of the property in circumstances in which subsection 66.7(4) applied, that subsection continued to apply to the taxpayer in respect of the original disposition as if subsequent successors were the same person as the taxpayer, and each designation made under subparagraph 66.7(4)(a)(iii) in respect of an amount that became receivable before the particular time were made before the particular time, the amount, if any, by which the total of all amounts each of which became receivable at or before the particular time and before 1993 by the taxpayer and is included in computing the amount determined under subparagraph 66.7(5)(a)(ii) in respect of the original disposition exceeds the amount, if any, by which where the taxpayer disposed of all or part of the property before the particular time in circumstances in which subsection 66.7(5) applied, the amount that would be determined at the particular time under subparagraph 66.7(5)(a)(i) in respect of the original disposition if that subparagraph continued to apply to the taxpayer in respect of the original disposition as if subsequent successors were the same person as the taxpayer, and in any other case, the amount determined at the particular time under subparagraph 66.7(5)(a)(i) in respect of the original disposition exceeds the amount that would be determined at the particular time under subparagraph 66.7(5)(a)(ii) in respect of the original disposition if that subparagraph were read without reference to the words “or the successor”, wherever they appear therein, and if amounts that became receivable after 1992 were not taken into account, and where after the original disposition and at or before the particular time, the taxpayer disposed of all or part of the property in circumstances in which subsection 66.7(4) applied, otherwise than by way of an amalgamation or merger or solely because of the application of paragraph 66.7(10)(c), and the winding-up of the taxpayer began at or before that time or the taxpayer’s disposition referred to in subparagraph (i) (other than a disposition under an agreement in writing entered into before December 22, 1992) occurred after December 21, 1992, nil M is the total amount of assistance that the taxpayer has received or is entitled to receive in respect of any Canadian development expense (including an expense that has become a Canadian exploration expense of the taxpayer by virtue of subsection 66.1(9)) incurred after 1980 or that can reasonably be related to Canadian development activities after 1980, M.1 is the total of all amounts by which the cumulative Canadian development expense of the taxpayer is required because of subsection 80(8) to be reduced at or before that time, N is the total of all amounts that are required to be deducted before that time under subsection 66(14.2) in computing the taxpayer’s cumulative Canadian development expense, and O is the total of all amounts that are required to be deducted before that time under paragraph 66.7(12)(c) in computing the taxpayer’s cumulative Canadian development expense.
    Full text

    cumulative Canadian development expense of a taxpayer at any time in a taxation year means the amount determined by the formula(A+B+C+D+D.1) - (E+F+G+H+I+J+K+L+M+M.1+N+O) where A is the total of all Canadian development expenses made or incurred by the taxpayer before that time, B is the total of all amounts that were, because of subsection (1), included in computing the amount referred to in paragraph 59(3.2)(c) for taxation years ending before that time, C is the total of all amounts referred to in the description of F or G that are established by the taxpayer to have become bad debts before that time, D is such part, if any, of the amount determined for M as has been repaid before that time by the taxpayer pursuant to a legal obligation to repay all or any part of that amount, D.1 is the total of all specified amounts, determined under paragraph 66.7(12.1)(b) in respect of the taxpayer for taxation years ending before that time, E is the total of all amounts deducted in computing the taxpayer’s income for a taxation year ending before that time in respect of the taxpayer’s cumulative Canadian development expense, F is the total of all amounts each of which is an amount in respect of property described in paragraph (b), (e) or (f) of the definition Canadian resource property in subsection 66(15) or property disposed of after March 21, 2011 which was described in any of those paragraphs and the cost of which when acquired by the taxpayer was included in the Canadian development expense of the taxpayer, or any right to or interest in — or, for civil law, any right in or to — such a property, other than such a right or an interest that the taxpayer has by reason of being a beneficiary under a trust or a member of a partnership, (in this description referred to as “the particular property”) disposed of by the taxpayer before that time equal to the amount, if any, by which the amount, if any, by which the proceeds of disposition in respect of the particular property that became receivable by the taxpayer after May 6, 1974 and before that time exceed any outlays or expenses that were made or incurred by the taxpayer after May 6, 1974 and before that time for the purpose of making the disposition and that were not otherwise deductible for the purposes of this Part exceeds the amount, if any, by which the total of all amounts that would be determined under paragraph 66.7(4)(a), immediately before the time (in this paragraph referred to as the “relevant time”) when such proceeds of disposition became receivable, in respect of the taxpayer and an original owner of the particular property (or of any other property acquired by the taxpayer with the particular property in circumstances in which subsection 66.7(4) applied and in respect of which the proceeds of disposition became receivable by the taxpayer at the relevant time) if amounts that became receivable at or after the relevant time were not taken into account, each designation made under subparagraph 66.7(4)(a)(iii) in respect of an amount that became receivable before the relevant time were made before the relevant time, paragraph 66.7(4)(a) were read without reference to “30% of”, and no reduction under subsection 80(8) at or after the relevant time were taken into account exceeds the total of all amounts that would be determined under paragraph 66.7(4)(a) at the relevant time in respect of the taxpayer and an original owner of the particular property (or of that other property) if amounts that became receivable after the relevant time were not taken into account, each designation made under subparagraph 66.7(4)(a)(iii) in respect of an amount that became receivable at or before the relevant time were made before the relevant time, paragraph 66.7(4)(a) were read without reference to “30% of”, amounts described in subparagraph 66.7(4)(a)(iii) that became receivable at the relevant time were not taken into account, and no reduction under subsection 80(8) at or after the relevant time were taken into account, and such portion of the amount otherwise determined under this paragraph as was otherwise applied to reduce the amount otherwise determined under this description, G is the total of all amounts that became receivable by the taxpayer before that time that are to be included in the amount determined under this description by virtue of paragraph 66(12.1)(b) or 66(12.3)(a), H is the total of all amounts each of which is an amount included by the taxpayer as an expense under paragraph (a) of the definition Canadian development expense in this subsection in computing the taxpayer’s Canadian development expense for a previous taxation year that has become a Canadian exploration expense of the taxpayer by virtue of subparagraph (c)(ii) of the definition Canadian exploration expense in subsection 66.1(6), I is the total of all amounts each of which is an amount that before that time has become a Canadian exploration expense of the taxpayer by virtue of subsection 66.1(9), J is the total of all amounts each of which is an amount received before that time on account of any amount referred to in the description of C K is the total of all amounts paid to the taxpayer after May 6, 1974 and before May 25, 1976 under the Northern Mineral Exploration Assistance Regulations made under an appropriation Act that provides for payments in respect of the Northern Mineral Grants Program, or pursuant to any agreement, entered into between the taxpayer and Her Majesty in right of Canada under the Northern Mineral Grants Program or the Development Program of the Department of Indian Affairs and Northern Development, to the extent that the amounts have been expended by the taxpayer as or on account of Canadian development expense incurred by the taxpayer, L is the amount by which the total of all amounts determined under subsection 66.4(1) in respect of a taxation year of the taxpayer ending at or before that time exceeds the total of all amounts each of which is the least of the amount that would be determined under paragraph 66.7(4)(a), at a time (hereafter in this description referred to only as the “particular time”) that is the end of the latest taxation year of the taxpayer ending at or before that time, in respect of the taxpayer as successor in respect of a disposition (in this description referred to as the “original disposition”) of Canadian resource property by a person who is an original owner of the property because of the original disposition, if that paragraph were read without reference to “30% of”, where the taxpayer has disposed of all or part of the property in circumstances in which subsection 66.7(4) applied, that subsection continued to apply to the taxpayer in respect of the original disposition as if subsequent successors were the same person as the taxpayer, and each designation made under subparagraph 66.7(4)(a)(iii) in respect of an amount that became receivable before the particular time were made before the particular time, the amount, if any, by which the total of all amounts each of which became receivable at or before the particular time and before 1993 by the taxpayer and is included in computing the amount determined under subparagraph 66.7(5)(a)(ii) in respect of the original disposition exceeds the amount, if any, by which where the taxpayer disposed of all or part of the property before the particular time in circumstances in which subsection 66.7(5) applied, the amount that would be determined at the particular time under subparagraph 66.7(5)(a)(i) in respect of the original disposition if that subparagraph continued to apply to the taxpayer in respect of the original disposition as if subsequent successors were the same person as the taxpayer, and in any other case, the amount determined at the particular time under subparagraph 66.7(5)(a)(i) in respect of the original disposition exceeds the amount that would be determined at the particular time under subparagraph 66.7(5)(a)(ii) in respect of the original disposition if that subparagraph were read without reference to the words “or the successor”, wherever they appear therein, and if amounts that became receivable after 1992 were not taken into account, and where after the original disposition and at or before the particular time, the taxpayer disposed of all or part of the property in circumstances in which subsection 66.7(4) applied, otherwise than by way of an amalgamation or merger or solely because of the application of paragraph 66.7(10)(c), and the winding-up of the taxpayer began at or before that time or the taxpayer’s disposition referred to in subparagraph (i) (other than a disposition under an agreement in writing entered into before December 22, 1992) occurred after December 21, 1992, nil M is the total amount of assistance that the taxpayer has received or is entitled to receive in respect of any Canadian development expense (including an expense that has become a Canadian exploration expense of the taxpayer by virtue of subsection 66.1(9)) incurred after 1980 or that can reasonably be related to Canadian development activities after 1980, M.1 is the total of all amounts by which the cumulative Canadian development expense of the taxpayer is required because of subsection 80(8) to be reduced at or before that time, N is the total of all amounts that are required to be deducted before that time under subsection 66(14.2) in computing the taxpayer’s cumulative Canadian development expense, and O is the total of all amounts that are required to be deducted before that time under paragraph 66.7(12)(c) in computing the taxpayer’s cumulative Canadian development expense.

  4. 2011-12-15 to 2013-06-26 View Source
    cumulative Canadian development expense of a taxpayer at any time in a taxation year means the amount determined by the formula(A+B+C+D+D.1) - (E+F+G+H+I+J+K+L+M+M.1+N+O) where A is the total of all Canadian development expenses made or incurred by the taxpayer before that time, B is the total of all amounts required by virtue of subsection 66.2(1) to be included in computing the amount referred to in paragraph 59(3.2)(c) for taxation years ending before that time, C is the total of all amounts referred to in the description of F or G that are established by the taxpayer to have become bad debts before that time, D is such part, if any, of the amount determined for M as has been repaid before that time by the taxpayer pursuant to a legal obligation to repay all or any part of that amount, D.1 is the total of all specified amounts, determined under paragraph 66.7(12.1)(b) in respect of the taxpayer for taxation years ending before that time, E is the total of all amounts deducted in computing the taxpayer’s income for a taxation year ending before that time in respect of the taxpayer’s cumulative Canadian development expense, F is the total of all amounts each of which is an amount in respect of property described in paragraph (b), (e) or (f) of the definition Canadian resource property in subsection 66(15) or property disposed of after March 21, 2011 which was described in any of those paragraphs and the cost of which when acquired by the taxpayer was included in the Canadian development expense of the taxpayer, or any right to or interest in — or, for civil law, any right in or to — such a property, other than such a right or an interest that the taxpayer has by reason of being a beneficiary under a trust or a member of a partnership, (in this description referred to as “the particular property”) disposed of by the taxpayer before that time equal to the amount, if any, by which the amount, if any, by which the proceeds of disposition in respect of the particular property that became receivable by the taxpayer after May 6, 1974 and before that time exceed any outlays or expenses that were made or incurred by the taxpayer after May 6, 1974 and before that time for the purpose of making the disposition and that were not otherwise deductible for the purposes of this Part exceeds the amount, if any, by which the total of all amounts that would be determined under paragraph 66.7(4)(a), immediately before the time (in this paragraph referred to as the “relevant time”) when such proceeds of disposition became receivable, in respect of the taxpayer and an original owner of the particular property (or of any other property acquired by the taxpayer with the particular property in circumstances in which subsection 66.7(4) applied and in respect of which the proceeds of disposition became receivable by the taxpayer at the relevant time) if amounts that became receivable at or after the relevant time were not taken into account, each designation made under subparagraph 66.7(4)(a)(iii) in respect of an amount that became receivable before the relevant time were made before the relevant time, paragraph 66.7(4)(a) were read without reference to “30% of”, and no reduction under subsection 80(8) at or after the relevant time were taken into account exceeds the total of all amounts that would be determined under paragraph 66.7(4)(a) at the relevant time in respect of the taxpayer and an original owner of the particular property (or of that other property) if amounts that became receivable after the relevant time were not taken into account, each designation made under subparagraph 66.7(4)(a)(iii) in respect of an amount that became receivable at or before the relevant time were made before the relevant time, paragraph 66.7(4)(a) were read without reference to “30% of”, amounts described in subparagraph 66.7(4)(a)(iii) that became receivable at the relevant time were not taken into account, and no reduction under subsection 80(8) at or after the relevant time were taken into account, and such portion of the amount otherwise determined under this paragraph as was otherwise applied to reduce the amount otherwise determined under this description, G is the total of all amounts that became receivable by the taxpayer before that time that are to be included in the amount determined under this description by virtue of paragraph 66(12.1)(b) or 66(12.3)(a), H is the total of all amounts each of which is an amount included by the taxpayer as an expense under paragraph (a) of the definition Canadian development expense in this subsection in computing the taxpayer’s Canadian development expense for a previous taxation year that has become a Canadian exploration expense of the taxpayer by virtue of subparagraph (c)(ii) of the definition Canadian exploration expense in subsection 66.1(6), I is the total of all amounts each of which is an amount that before that time has become a Canadian exploration expense of the taxpayer by virtue of subsection 66.1(9), J is the total of all amounts each of which is an amount received before that time on account of any amount referred to in the description of C K is the total of all amounts paid to the taxpayer after May 6, 1974 and before May 25, 1976 under the Northern Mineral Exploration Assistance Regulations made under an appropriation Act that provides for payments in respect of the Northern Mineral Grants Program, or pursuant to any agreement, entered into between the taxpayer and Her Majesty in right of Canada under the Northern Mineral Grants Program or the Development Program of the Department of Indian Affairs and Northern Development, to the extent that the amounts have been expended by the taxpayer as or on account of Canadian development expense incurred by the taxpayer, L is the amount by which the total of all amounts determined under subsection 66.4(1) in respect of a taxation year of the taxpayer ending at or before that time exceeds the total of all amounts each of which is the least of the amount that would be determined under paragraph 66.7(4)(a), at a time (hereafter in this description referred to only as the “particular time”) that is the end of the latest taxation year of the taxpayer ending at or before that time, in respect of the taxpayer as successor in respect of a disposition (in this description referred to as the “original disposition”) of Canadian resource property by a person who is an original owner of the property because of the original disposition, if that paragraph were read without reference to “30% of”, where the taxpayer has disposed of all or part of the property in circumstances in which subsection 66.7(4) applied, that subsection continued to apply to the taxpayer in respect of the original disposition as if subsequent successors were the same person as the taxpayer, and each designation made under subparagraph 66.7(4)(a)(iii) in respect of an amount that became receivable before the particular time were made before the particular time, the amount, if any, by which the total of all amounts each of which became receivable at or before the particular time and before 1993 by the taxpayer and is included in computing the amount determined under subparagraph 66.7(5)(a)(ii) in respect of the original disposition exceeds the amount, if any, by which where the taxpayer disposed of all or part of the property before the particular time in circumstances in which subsection 66.7(5) applied, the amount that would be determined at the particular time under subparagraph 66.7(5)(a)(i) in respect of the original disposition if that subparagraph continued to apply to the taxpayer in respect of the original disposition as if subsequent successors were the same person as the taxpayer, and in any other case, the amount determined at the particular time under subparagraph 66.7(5)(a)(i) in respect of the original disposition exceeds the amount that would be determined at the particular time under subparagraph 66.7(5)(a)(ii) in respect of the original disposition if that subparagraph were read without reference to the words “or the successor”, wherever they appear therein, and if amounts that became receivable after 1992 were not taken into account, and where after the original disposition and at or before the particular time, the taxpayer disposed of all or part of the property in circumstances in which subsection 66.7(4) applied, otherwise than by way of an amalgamation or merger or solely because of the application of paragraph 66.7(10)(c), and the winding-up of the taxpayer began at or before that time or the taxpayer’s disposition referred to in subparagraph (i) (other than a disposition under an agreement in writing entered into before December 22, 1992) occurred after December 21, 1992, nil M is the total amount of assistance that the taxpayer has received or is entitled to receive in respect of any Canadian development expense (including an expense that has become a Canadian exploration expense of the taxpayer by virtue of subsection 66.1(9)) incurred after 1980 or that can reasonably be related to Canadian development activities after 1980, M.1 is the total of all amounts by which the cumulative Canadian development expense of the taxpayer is required because of subsection 80(8) to be reduced at or before that time, N is the total of all amounts that are required to be deducted before that time under subsection 66(14.2) in computing the taxpayer’s cumulative Canadian development expense, and O is the total of all amounts that are required to be deducted before that time under paragraph 66.7(12)(c) in computing the taxpayer’s cumulative Canadian development expense.
    Full text

    cumulative Canadian development expense of a taxpayer at any time in a taxation year means the amount determined by the formula(A+B+C+D+D.1) - (E+F+G+H+I+J+K+L+M+M.1+N+O) where A is the total of all Canadian development expenses made or incurred by the taxpayer before that time, B is the total of all amounts required by virtue of subsection 66.2(1) to be included in computing the amount referred to in paragraph 59(3.2)(c) for taxation years ending before that time, C is the total of all amounts referred to in the description of F or G that are established by the taxpayer to have become bad debts before that time, D is such part, if any, of the amount determined for M as has been repaid before that time by the taxpayer pursuant to a legal obligation to repay all or any part of that amount, D.1 is the total of all specified amounts, determined under paragraph 66.7(12.1)(b) in respect of the taxpayer for taxation years ending before that time, E is the total of all amounts deducted in computing the taxpayer’s income for a taxation year ending before that time in respect of the taxpayer’s cumulative Canadian development expense, F is the total of all amounts each of which is an amount in respect of property described in paragraph (b), (e) or (f) of the definition Canadian resource property in subsection 66(15) or property disposed of after March 21, 2011 which was described in any of those paragraphs and the cost of which when acquired by the taxpayer was included in the Canadian development expense of the taxpayer, or any right to or interest in — or, for civil law, any right in or to — such a property, other than such a right or an interest that the taxpayer has by reason of being a beneficiary under a trust or a member of a partnership, (in this description referred to as “the particular property”) disposed of by the taxpayer before that time equal to the amount, if any, by which the amount, if any, by which the proceeds of disposition in respect of the particular property that became receivable by the taxpayer after May 6, 1974 and before that time exceed any outlays or expenses that were made or incurred by the taxpayer after May 6, 1974 and before that time for the purpose of making the disposition and that were not otherwise deductible for the purposes of this Part exceeds the amount, if any, by which the total of all amounts that would be determined under paragraph 66.7(4)(a), immediately before the time (in this paragraph referred to as the “relevant time”) when such proceeds of disposition became receivable, in respect of the taxpayer and an original owner of the particular property (or of any other property acquired by the taxpayer with the particular property in circumstances in which subsection 66.7(4) applied and in respect of which the proceeds of disposition became receivable by the taxpayer at the relevant time) if amounts that became receivable at or after the relevant time were not taken into account, each designation made under subparagraph 66.7(4)(a)(iii) in respect of an amount that became receivable before the relevant time were made before the relevant time, paragraph 66.7(4)(a) were read without reference to “30% of”, and no reduction under subsection 80(8) at or after the relevant time were taken into account exceeds the total of all amounts that would be determined under paragraph 66.7(4)(a) at the relevant time in respect of the taxpayer and an original owner of the particular property (or of that other property) if amounts that became receivable after the relevant time were not taken into account, each designation made under subparagraph 66.7(4)(a)(iii) in respect of an amount that became receivable at or before the relevant time were made before the relevant time, paragraph 66.7(4)(a) were read without reference to “30% of”, amounts described in subparagraph 66.7(4)(a)(iii) that became receivable at the relevant time were not taken into account, and no reduction under subsection 80(8) at or after the relevant time were taken into account, and such portion of the amount otherwise determined under this paragraph as was otherwise applied to reduce the amount otherwise determined under this description, G is the total of all amounts that became receivable by the taxpayer before that time that are to be included in the amount determined under this description by virtue of paragraph 66(12.1)(b) or 66(12.3)(a), H is the total of all amounts each of which is an amount included by the taxpayer as an expense under paragraph (a) of the definition Canadian development expense in this subsection in computing the taxpayer’s Canadian development expense for a previous taxation year that has become a Canadian exploration expense of the taxpayer by virtue of subparagraph (c)(ii) of the definition Canadian exploration expense in subsection 66.1(6), I is the total of all amounts each of which is an amount that before that time has become a Canadian exploration expense of the taxpayer by virtue of subsection 66.1(9), J is the total of all amounts each of which is an amount received before that time on account of any amount referred to in the description of C K is the total of all amounts paid to the taxpayer after May 6, 1974 and before May 25, 1976 under the Northern Mineral Exploration Assistance Regulations made under an appropriation Act that provides for payments in respect of the Northern Mineral Grants Program, or pursuant to any agreement, entered into between the taxpayer and Her Majesty in right of Canada under the Northern Mineral Grants Program or the Development Program of the Department of Indian Affairs and Northern Development, to the extent that the amounts have been expended by the taxpayer as or on account of Canadian development expense incurred by the taxpayer, L is the amount by which the total of all amounts determined under subsection 66.4(1) in respect of a taxation year of the taxpayer ending at or before that time exceeds the total of all amounts each of which is the least of the amount that would be determined under paragraph 66.7(4)(a), at a time (hereafter in this description referred to only as the “particular time”) that is the end of the latest taxation year of the taxpayer ending at or before that time, in respect of the taxpayer as successor in respect of a disposition (in this description referred to as the “original disposition”) of Canadian resource property by a person who is an original owner of the property because of the original disposition, if that paragraph were read without reference to “30% of”, where the taxpayer has disposed of all or part of the property in circumstances in which subsection 66.7(4) applied, that subsection continued to apply to the taxpayer in respect of the original disposition as if subsequent successors were the same person as the taxpayer, and each designation made under subparagraph 66.7(4)(a)(iii) in respect of an amount that became receivable before the particular time were made before the particular time, the amount, if any, by which the total of all amounts each of which became receivable at or before the particular time and before 1993 by the taxpayer and is included in computing the amount determined under subparagraph 66.7(5)(a)(ii) in respect of the original disposition exceeds the amount, if any, by which where the taxpayer disposed of all or part of the property before the particular time in circumstances in which subsection 66.7(5) applied, the amount that would be determined at the particular time under subparagraph 66.7(5)(a)(i) in respect of the original disposition if that subparagraph continued to apply to the taxpayer in respect of the original disposition as if subsequent successors were the same person as the taxpayer, and in any other case, the amount determined at the particular time under subparagraph 66.7(5)(a)(i) in respect of the original disposition exceeds the amount that would be determined at the particular time under subparagraph 66.7(5)(a)(ii) in respect of the original disposition if that subparagraph were read without reference to the words “or the successor”, wherever they appear therein, and if amounts that became receivable after 1992 were not taken into account, and where after the original disposition and at or before the particular time, the taxpayer disposed of all or part of the property in circumstances in which subsection 66.7(4) applied, otherwise than by way of an amalgamation or merger or solely because of the application of paragraph 66.7(10)(c), and the winding-up of the taxpayer began at or before that time or the taxpayer’s disposition referred to in subparagraph (i) (other than a disposition under an agreement in writing entered into before December 22, 1992) occurred after December 21, 1992, nil M is the total amount of assistance that the taxpayer has received or is entitled to receive in respect of any Canadian development expense (including an expense that has become a Canadian exploration expense of the taxpayer by virtue of subsection 66.1(9)) incurred after 1980 or that can reasonably be related to Canadian development activities after 1980, M.1 is the total of all amounts by which the cumulative Canadian development expense of the taxpayer is required because of subsection 80(8) to be reduced at or before that time, N is the total of all amounts that are required to be deducted before that time under subsection 66(14.2) in computing the taxpayer’s cumulative Canadian development expense, and O is the total of all amounts that are required to be deducted before that time under paragraph 66.7(12)(c) in computing the taxpayer’s cumulative Canadian development expense.

  5. 2004-08-31 to 2011-12-15 View Source

    cumulative Canadian development expense of a taxpayer at any time in a taxation year means the amount determined by the formula(A+B+C+D+D.1) - (E+F+G+H+I+J+K+L+M+M.1+N+O) where A is the total of all Canadian development expenses made or incurred by the taxpayer before that time, B is the total of all amounts required by virtue of subsection 66.2(1) to be included in computing the amount referred to in paragraph 59(3.2)(c) for taxation years ending before that time, C is the total of all amounts referred to in the description of F or G that are established by the taxpayer to have become bad debts before that time, D is such part, if any, of the amount determined for M as has been repaid before that time by the taxpayer pursuant to a legal obligation to repay all or any part of that amount, D.1 is the total of all specified amounts, determined under paragraph 66.7(12.1)(b) in respect of the taxpayer for taxation years ending before that time, E is the total of all amounts deducted in computing the taxpayer’s income for a taxation year ending before that time in respect of the taxpayer’s cumulative Canadian development expense, F is the total of all amounts each of which is an amount in respect of property described in paragraph (b), (e) or (f) of the definition Canadian resource property in subsection 66(15) or any right to or interest in such a property, other than such a right or an interest that the taxpayer has by reason of being a beneficiary under a trust or a member of a partnership, (in this description referred to as “the particular property”) disposed of by the taxpayer before that time equal to the amount, if any, by which the amount, if any, by which the proceeds of disposition in respect of the particular property that became receivable by the taxpayer after May 6, 1974 and before that time exceed any outlays or expenses that were made or incurred by the taxpayer after May 6, 1974 and before that time for the purpose of making the disposition and that were not otherwise deductible for the purposes of this Part exceeds the amount, if any, by which the total of all amounts that would be determined under paragraph 66.7(4)(a), immediately before the time (in this paragraph referred to as the “relevant time”) when such proceeds of disposition became receivable, in respect of the taxpayer and an original owner of the particular property (or of any other property acquired by the taxpayer with the particular property in circumstances in which subsection 66.7(4) applied and in respect of which the proceeds of disposition became receivable by the taxpayer at the relevant time) if amounts that became receivable at or after the relevant time were not taken into account, each designation made under subparagraph 66.7(4)(a)(iii) in respect of an amount that became receivable before the relevant time were made before the relevant time, paragraph 66.7(4)(a) were read without reference to “30% of”, and no reduction under subsection 80(8) at or after the relevant time were taken into account exceeds the total of all amounts that would be determined under paragraph 66.7(4)(a) at the relevant time in respect of the taxpayer and an original owner of the particular property (or of that other property) if amounts that became receivable after the relevant time were not taken into account, each designation made under subparagraph 66.7(4)(a)(iii) in respect of an amount that became receivable at or before the relevant time were made before the relevant time, paragraph 66.7(4)(a) were read without reference to “30% of”, amounts described in subparagraph 66.7(4)(a)(iii) that became receivable at the relevant time were not taken into account, and no reduction under subsection 80(8) at or after the relevant time were taken into account, and such portion of the amount otherwise determined under this paragraph as was otherwise applied to reduce the amount otherwise determined under this description, G is the total of all amounts that became receivable by the taxpayer before that time that are to be included in the amount determined under this description by virtue of paragraph 66(12.1)(b) or 66(12.3)(a), H is the total of all amounts each of which is an amount included by the taxpayer as an expense under paragraph (a) of the definition Canadian development expense in this subsection in computing the taxpayer’s Canadian development expense for a previous taxation year that has become a Canadian exploration expense of the taxpayer by virtue of subparagraph (c)(ii) of the definition Canadian exploration expense in subsection 66.1(6), I is the total of all amounts each of which is an amount that before that time has become a Canadian exploration expense of the taxpayer by virtue of subsection 66.1(9), J is the total of all amounts each of which is an amount received before that time on account of any amount referred to in the description of C K is the total of all amounts paid to the taxpayer after May 6, 1974 and before May 25, 1976 under the Northern Mineral Exploration Assistance Regulations made under an appropriation Act that provides for payments in respect of the Northern Mineral Grants Program, or pursuant to any agreement, entered into between the taxpayer and Her Majesty in right of Canada under the Northern Mineral Grants Program or the Development Program of the Department of Indian Affairs and Northern Development, to the extent that the amounts have been expended by the taxpayer as or on account of Canadian development expense incurred by the taxpayer, L is the amount by which the total of all amounts determined under subsection 66.4(1) in respect of a taxation year of the taxpayer ending at or before that time exceeds the total of all amounts each of which is the least of the amount that would be determined under paragraph 66.7(4)(a), at a time (hereafter in this description referred to only as the “particular time”) that is the end of the latest taxation year of the taxpayer ending at or before that time, in respect of the taxpayer as successor in respect of a disposition (in this description referred to as the “original disposition”) of Canadian resource property by a person who is an original owner of the property because of the original disposition, if that paragraph were read without reference to “30% of”, where the taxpayer has disposed of all or part of the property in circumstances in which subsection 66.7(4) applied, that subsection continued to apply to the taxpayer in respect of the original disposition as if subsequent successors were the same person as the taxpayer, and each designation made under subparagraph 66.7(4)(a)(iii) in respect of an amount that became receivable before the particular time were made before the particular time, the amount, if any, by which the total of all amounts each of which became receivable at or before the particular time and before 1993 by the taxpayer and is included in computing the amount determined under subparagraph 66.7(5)(a)(ii) in respect of the original disposition exceeds the amount, if any, by which where the taxpayer disposed of all or part of the property before the particular time in circumstances in which subsection 66.7(5) applied, the amount that would be determined at the particular time under subparagraph 66.7(5)(a)(i) in respect of the original disposition if that subparagraph continued to apply to the taxpayer in respect of the original disposition as if subsequent successors were the same person as the taxpayer, and in any other case, the amount determined at the particular time under subparagraph 66.7(5)(a)(i) in respect of the original disposition exceeds the amount that would be determined at the particular time under subparagraph 66.7(5)(a)(ii) in respect of the original disposition if that subparagraph were read without reference to the words “or the successor”, wherever they appear therein, and if amounts that became receivable after 1992 were not taken into account, and where after the original disposition and at or before the particular time, the taxpayer disposed of all or part of the property in circumstances in which subsection 66.7(4) applied, otherwise than by way of an amalgamation or merger or solely because of the application of paragraph 66.7(10)(c), and the winding-up of the taxpayer began at or before that time or the taxpayer’s disposition referred to in subparagraph (i) (other than a disposition under an agreement in writing entered into before December 22, 1992) occurred after December 21, 1992, nil M is the total amount of assistance that the taxpayer has received or is entitled to receive in respect of any Canadian development expense (including an expense that has become a Canadian exploration expense of the taxpayer by virtue of subsection 66.1(9)) incurred after 1980 or that can reasonably be related to Canadian development activities after 1980, M.1 is the total of all amounts by which the cumulative Canadian development expense of the taxpayer is required because of subsection 80(8) to be reduced at or before that time, N is the total of all amounts that are required to be deducted before that time under subsection 66(14.2) in computing the taxpayer’s cumulative Canadian development expense, and O is the total of all amounts that are required to be deducted before that time under paragraph 66.7(12)(c) in computing the taxpayer’s cumulative Canadian development expense.