Income Tax Act — I-3.3 37
 prosecution, of scientific research and experimental development in Canada, (II) an expenditure of a current nature directly attributable, as determined by regulation, to the prosecution, or to the provision of premises, facilities or equipment for the prosecution, of scientific research and experimental development in Canada, or (III) an expenditure of a capital nature that, at the time it was incurred, was for the provision of premises, facilities or equipment, where at that time it was intended that it would be used during all or substantially all of its operating time in its expected useful life for — or that all or substantially all of its value would be consumed in — the prosecution of scientific research and experimental development in Canada, and (B) where a taxpayer has elected in prescribed form and in accordance with subsection 37(10) for a taxation year, expenditures incurred by the taxpayer in the year each of which is (I) an expenditure of a current nature for, and all or substantially all of which was attributable to, the lease of premises, facilities or equipment for the prosecution of scientific research and experimental development in Canada, other than an expenditure in respect of general purpose office equipment or furniture, (II) an expenditure for the prosecution of scientific research and experimental development in Canada directly undertaken on behalf of the taxpayer, (III) an expenditure described in subclause (A)(III), other than an expenditure in respect of general purpose office equipment or furniture, (IV) that portion of an expenditure made in respect of an expense incurred in the year for salary or wages of an employee who is directly engaged in scientific research and experimental development in Canada that can reasonably be considered to relate to such work having regard to the time spent by the employee thereon, and, for this purpose, where that portion is all or substantially all of the expenditure, that portion shall be deemed to be the amount of the expenditure, (V) the cost of materials consumed or transformed in the prosecution of scientific research and experimental development in Canada, or (VI) 1/2 of any other expenditure of a current nature in respect of the lease of premises, facilities or equipment used primarily for the prosecution of scientific research and experimental development in Canada, other than an expenditure in respect of general purpose office equipment or furniture; (b) for greater certainty, references to scientific research and experimental development related to a business include any scientific research and experimental development that may lead to or facilitate an extension of that business; (c) except in the case of a taxpayer who derives all or substantially all of the taxpayer’s revenue from the prosecution of scientific research and experimental development (including the sale of rights arising out of scientific research and experimental development carried on by the taxpayer), the prosecution of scientific research and experimental development shall not be considered to be a business of the taxpayer to which scientific research and experimental development is related; (d) references to expenditures of a current nature include any expenditure made by a taxpayer other than an expenditure made by the taxpayer for (i) the acquisition from a person or partnership of a property that is a capital property of the taxpayer, or (ii) the use of, or the right to use, property that would be capital property of the taxpayer if it were owned by the taxpayer, and (e) despite paragraph (a), references to expenditures on or in respect of scientific research and experimental development must not include (i) any capital expenditure made in respect of the acquisition of a building or a leasehold interest therein, other than a prescribed special-purpose building, (ii) any outlay or expense made or incurred for the use of, or the right to use, a building other than a prescribed s