Income Tax Act — I-3.3 66.21
source property relates, (i) an expenditure, incurred at any time, that relates 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 incurred by the taxpayer, unless the expenditure was made (i) for the acquisition of foreign resource property by the taxpayer, or (ii) 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, or (k) the taxpayer’s share of any cost or expenditure referred to in any of paragraphs (f) to (j) that is incurred by a partnership. ( frais relatifs à des ressources à l’étranger ) foreign resource income of a taxpayer for a taxation year, in respect of a country other than Canada, means the total of (a) that part of the taxpayer’s income for the year, determined without reference to subsections (4) and 66(4), that is reasonably attributable to (i) the production of petroleum or natural gas from natural accumulations of petroleum or natural gas in that country or from oil or gas wells in that country, or (ii) the production of minerals from mines in that country; (b) the taxpayer’s income for the year from royalties in respect of a natural accumulation of petroleum or natural gas in that country, an oil or gas well in that country or a mine in that country, determined without reference to subsections (4) and 66(4); and (c) all amounts each of which is an amount, in respect of a foreign resource property in respect of that country that has been disposed of by the taxpayer, equal to the amount, if any, by which (i) the amount included in computing the taxpayer’s income for the year by reason of subsection 59(1) in respect of that disposition exceeds (ii) the total of all amounts each of which is that portion of an amount deducted under subsection 66.7(2) in computing the taxpayer’s income for the year that (A) can reasonably be considered to be in respect of the foreign resource property, and (B) cannot reasonably be considered to have reduced the amount otherwise determined under paragraph (a) or (b) in respect of the taxpayer for the year. ( revenu provenant de ressources à l’étranger ) foreign resource loss of a taxpayer for a taxation year in respect of a country other than Canada means the taxpayer’s loss for the year in respect of the country determined in accordance with the definition foreign resource income with such modifications as the circumstances require. ( perte résultant de ressources à l’étranger ) global foreign resource limit of a taxpayer for a taxation year means the amount that is the lesser of (a) the amount, if any, by which (i) the amount determined under subparagraph 66(4)(b)(ii) in respect of the taxpayer for the year exceeds the total of (ii) the total of all amounts each of which is the maximum amount that the taxpayer would be permitted to deduct, in respect of a country, under subsection (4) in computing the taxpayer’s income for the year if, in its application to the year, subsection (4) were read without reference to paragraph (4)(b), and (iii) the amount deducted for the year under subsection 66(4) in computing the taxpayer’s income for the year; and (b) the amount, if any, by which (i) 30% of the total of all amounts each of which is, at the end of the year, the taxpayer’s adjusted cumulative foreign resource expense in respect of a country exceeds (ii) the total described in subparagraph (a)(ii). ( limite globale des frais relatifs à des ressources à l’étranger ) Application of subsection 66(15) (2) The definitions in subsection 66(15) apply in this section. Amount to be included in income (3) For the purpose of paragraph 59(3.2)(c.1), the amount referred to in this subsection in respect of a taxpayer for a taxation y