Income Tax Act — I-3.3 66.21
d (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 by reason of subsection 66(12.41) that became receivable by the taxpayer before the particular time and at a resident time; H is the total of all amounts each of which is an amount received before the particular time and at a resident time on account of any amount referred to in the description of C; I is the total of all amounts each of which is an amount by which the cumulative foreign resource expense of the taxpayer, in respect of that country, is required, by reason of subsection 80(8), to be reduced at or before the particular time and at a resident time; and J is the total of all amounts each of which is an amount that is required to be deducted, before the particular time and at a resident time, under paragraph 66.7(13.1)(a) in computing the taxpayer’s cumulative foreign resource expense. ( frais cumulatifs relatifs à des ressources à l’étranger ) foreign resource expense of a taxpayer, in respect of a country other than Canada, means (a) any drilling or exploration expense, including any general geological or geophysical expense, incurred by the taxpayer on or in respect of exploring or drilling for petroleum or natural gas in that country, (b) any expense incurred by the taxpayer for the purpose of determining the existence, location, extent or quality of a mineral resource in that country, including any expense incurred in the course of (i) prospecting, (ii) carrying out geological, geophysical or geochemical surveys, (iii) drilling by rotary, diamond, percussion or other methods, or (iv) trenching, digging test pits and preliminary sampling, (c) the cost to the taxpayer of any of the taxpayer’s foreign resource property in respect of that country, (d) any annual payment made by the taxpayer for the preservation of a foreign resource property in respect of that country, and (e) subject to section 66.8, the taxpayer’s share of an expense, cost or payment referred to in any of paragraphs (a) to (d) that is made or incurred by a partnership in a fiscal period of the partnership that begins after 2000 if, at the end of that period, the taxpayer was a member of the partnership but does not include (f) an expenditure that is the cost, or any part of the 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, that relates to the injection of any substance to assist in the recovery of petroleum, natural gas or related hydrocarbons from a nat