Income Tax Act — I-3.3 (a)
cumulative foreign resource expense of a taxpayer, in respect of a country other than Canada at a particular time, means the amount determined by the formula (A + A.1 + B + C + D) – (E + F + G + H + I + J) where A is the total of all foreign resource expenses, in respect of that country, made or incurred by the taxpayer (a) before the particular time, and (b) at a time (in this definition referred to as a “resident time”) (i) at which the taxpayer was resident in Canada, and (ii) where the taxpayer became resident in Canada before the particular time, that is after the last time (before the particular time) that the taxpayer became resident in Canada; A.1 is the total of all foreign resource expenses, in respect of that country, that is the cost to the taxpayer of any of the taxpayer’s foreign resource property in respect of that country that is deemed to have been acquired by the taxpayer under paragraph 128.1(1)(c) at the last time (before the particular time) that the taxpayer became resident in Canada; B is the total of all amounts included in computing the amount referred to in paragraph 59(3.2)(c.1) in respect of that country, for taxation years that ended before the particular time and at a resident 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 a bad debt before the particular time and at a resident time; D is the total of all specified amounts determined under subsection 66.7(13.2), in respect of the taxpayer and that country, for taxation years that ended before the particular time and at a resident time; E is the total of all amounts deducted, in computing the taxpayer’s income for a taxation year that ended before the particular time and at a resident time, in respect of the taxpayer’s cumulative foreign resource expense in respect of that country; F is the total of all amounts each of which is an amount in respect of a foreign resource property, in respect of that country, (in this description referred to as the “particular property”) disposed of by the taxpayer equal to the amount, if any, by which (a) the amount designated under subparagraph 59(1)(b)(ii) by the taxpayer in respect of the portion of the proceeds of that disposition that became receivable before the particular time and at a resident time exceeds (b) the amount, if any, by which (i) the total of all amounts that would be determined under paragraph 66.7(2.3)(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, that country and an original owner of the particular property (or of any other property acquired by the taxpayer with the particular property in circumstances to which subsection 66.7(2.3) 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) paragraph 66.7(2.3)(a) were read without reference to “30% of”, and (C) 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(2.3)(a) at the relevant time in respect of the taxpayer, that country 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) paragraph 66.7(2.3)(a) were read without reference to “30% of”, and (C) no reduction under subsection 80(8) at or after the relevant time were taken into account, and (iii) the portion of the amount otherwise determined under this paragraph that was otherwise applied to reduce the amount otherwise determined under this description; G is the total of all amounts, in respect of that country, each of which is an amount included in the amount determined under this description b