Income Tax Act — I-3.3 (a)
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 (a) 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 (b) the amount, if any, by which (i) 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 (A) amounts that became receivable at or after the relevant time were not taken into account, (B) 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, (C) paragraph 66.7(4)(a) were read without reference to “30% of”, and (D) no reduction under subsection 80(8) at or after the relevant time were taken into account exceeds the total of (ii) 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 (A) amounts that became receivable after the relevant time were not taken into account, (B) 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, (C) paragraph 66.7(4)(a) were read without reference to “30% of”, (D) amounts described in subparagraph 66.7(4)(a)(iii) that became receivable at the relevant time were not taken into account, and (E) no redu