By virtue of being a member of a partnership (SENC), Mr. X was allocated his share of Canadian development expense (CDE) incurred by a corporation whose flow-through shares were held by SENC, and deducted 30% of his resulting CCDE balance for that year. In the subsequent year of his death, can there be any recognition of his remaining CCDE balance? CRA responded:
No further deduction would be available in respect of the unamortized balance of the CCDE and the unutilized balance of the CCDE could not be transferred to Mr. X's estate.