Income Tax Act — I-3.3 66
e taxpayer of any foreign resource property acquired by him, (d) subject to section 66.8, the taxpayer’s share of the foreign exploration and development expenses incurred after 1971 by a partnership in a fiscal period thereof, if at the end of that period the taxpayer was a member of the partnership, and (e) any annual payment made by the taxpayer for the preservation of a foreign resource property; but does not include (f) any amount included at any time in the capital cost to the taxpayer of any depreciable property of a prescribed class, (g) an expenditure incurred at any time after the commencement of production from a foreign resource property of the taxpayer in order to evaluate the feasibility of a method of recovery of petroleum, natural gas or related hydrocarbons from the portion of a natural reservoir to which the foreign resource property relates, (h) an expenditure (other than a drilling expense) incurred at any time after the commencement of production from a foreign resource property of the taxpayer in order to assist in the recovery of petroleum, natural gas or related hydrocarbons from the portion of a natural reservoir to which the foreign resource property relates, (i) an expenditure incurred at any time relating to the injection of any substance to assist in the recovery of petroleum, natural gas or related hydrocarbons from a natural reservoir, (j) an expenditure that is the cost, or any part of the cost, to the taxpayer of any depreciable property of a prescribed class that was acquired after December 21, 2000, (k) foreign resource expenses in respect of a country, or (l) an expenditure made after February 27, 2000 by the taxpayer unless the expenditure was made (i) pursuant to an agreement in writing made by the taxpayer before February 28, 2000, (ii) for the acquisition of foreign resource property by the taxpayer, or (iii) for the purpose of (A) enhancing the value of foreign resource property that the taxpayer owned at the time the expenditure was incurred or that the taxpayer had a reasonable expectation of owning after that time, or (B) assisting in evaluating whether a foreign resource property is to be acquired by the taxpayer; ( frais d’exploration et d’aménagement à l’étranger ) foreign resource property of a taxpayer means any property that would be a Canadian resource property of the taxpayer if the definition Canadian resource property in this subsection were read as if the references therein to “in Canada” were references to “outside Canada”; ( avoir minier étranger ) joint exploration corporation means a principal-business corporation that has not at any time since its incorporation had more than 10 shareholders, not including any individual holding a share for the sole purpose of qualifying as a director; ( société d’exploration en commun ) original owner of a Canadian resource property or a foreign resource property means a person (a) who owned the property and disposed of it to a corporation that acquired it in circumstances in which subsection 29(25) of the Income Tax Application Rules or subsection 66.7(1), (2), (2.3), (3), (4) or (5) applies, or would apply if the corporation had continued to own the property, to the corporation in respect of the property, and (b) who would, but for subsection 66.7(12), (13), (13.1) or (17), as the case may be, be entitled in computing that person’s income for a taxation year that ends after that person disposed of the property to a deduction under section 29 of the Income Tax Application Rules or subsection (2), (3) or (4), 66.1(2) or (3), 66.2(2), 66.21(4) or 66.4(2) of this Act in respect of expenses described in subparagraph 29(25)(c)(i) or (ii) of that Act, Canadian exploration and development expenses, foreign resource pool expenses, Canadian exploration expenses, Canadian development expenses or Canadian oil and gas property expenses incurred by the person before the person disposed of the property; ( propriétaire obligé ) outlay , made before