Income Tax Regulations — 808
808 (1) For the purposes of paragraph 219(1)(j) of the Act, the allowance of a corporation (other than an authorized foreign bank) for a taxation year in respect of its investment in property in Canada is prescribed to be the amount, if any, by which (a) the corporation’s qualified investment in property in Canada at the end of the year, exceeds (b) the amount determined under this paragraph for the immediately preceding taxation year. (1.1) Notwithstanding subsections (1) and (8), for the purpose of paragraph 219(1)(j) of the Act, the allowance of a corporation that becomes resident in Canada at any time is, in respect of its investment in property in Canada for its last taxation year that ends before that time, prescribed to be nil. (2) For the purposes of subsection (1), where, at the end of a taxation year, a corporation is not a member of a partnership that was carrying on business in Canada at any time in the year, the corporation’s “qualified investment in property in Canada at the end of the year” is the amount, if any, by which the aggregate of (a) the cost amount to the corporation, at the end of the year, of land in Canada owned by it at that time for the purpose of gaining or producing income from a business carried on by it in Canada, other than land that is (i) described in the corporation’s inventory, (ii) depreciable property, (iii) a Canadian resource property, or (iv) land the cost of which is or was deductible in computing the corporation’s income, (b) an amount equal to the aggregate of the cost amount to the corporation, immediately after the end of the year, of each depreciable property in Canada owned by it for the purpose of gaining or producing income from a business carried on by it in Canada, (c) [Repealed, 2016, c. 12, s. 77] (d) where the corporation is not a principal-business corporation, within the meaning assigned by subsection 66(15) of the Act, an amount equal to the total of the corporation’s (i) Canadian exploration and development expenses incurred by the corporation before the end of the year, except to the extent that those expenses were deducted in computing the corporation’s income for the year or for a previous taxation year, and (ii) cumulative Canadian exploration expense, within the meaning assigned by subsection 66.1(6) of the Act, at the end of the year minus any deduction under subsection 66.1(3) of the Act in computing the corporation’s income for the year, (d.1) an amount equal to the corporation’s cumulative Canadian development expense, within the meaning assigned by subsection 66.2(5) of the Act, at the end of the year minus any deduction under subsection 66.2(2) of the Act in computing the corporation’s income for the year, (d.2) an amount equal to the corporation’s cumulative Canadian oil and gas property expense, within the meaning assigned by subsection 66.4(5) of the Act, at the end of the year minus any deduction under subsection 66.4(2) of the Act in computing the corporation’s income for the year, (e) an amount equal to the aggregate of the cost amount to the corporation at the end of the year of each debt owing to it, or any other right of the corporation to receive an amount, that was outstanding as a result of the disposition by it of property in respect of which an amount would be included, by virtue of paragraph (a), (b) or (h), in its qualified investment in property in Canada at the end of the year if the property had not been disposed of by it before the end of that year, (f) an amount equal to the aggregate of the cost amount to the corporation at the end of the year of each property, other than a Canadian resource property, that was described in the corporation’s inventory in respect of a business carried on by it in Canada, (g) an amount equal to the aggregate of the cost amount to the corporation at the end of the year of each debt (other than a debt referred to in paragraph (e) or a debt the amount of which was deducted under paragraph 20(1)(p) of the A