If an issuer intends only to realize capital gains from 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 … is not in itself a source of income that is property.