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?
After noting that “[n]o 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,” CRA went on to state:
[S]ubsection 70(5.2), which sets out the rules applicable where a taxpayer who owns a Canadian resource property dies in a taxation year, would not be applicable … since it is our position that Mr. X's interest in SENC would not constitute a "Canadian resource property" … .