If an issuer does not expect to earn income from property, but rather intends to only realize capital gains (or losses) from the disposition of its investments, would its issue expenses be deductible under the s. 20(1)(e)(i)? CRA responded:
No amount can be deductible under subparagraph 20(1)(e)(i) if there is not a source of income that is a business or property. … As a result [of s. 9(3)], the appreciation in the value of a property that is capital property (as defined in section 54) is not in itself a source of income that is property.