Class 14.1 depreciable property references “property” of the taxpayer. Does this have the effect of disqualifying, as Class 14.1 additions, capital expenditures, such as legal costs of aborted acquisitions, that potentially could have qualified as eligible capital expenditures if incurred before 2017, as Class 14.1 property additions if incurred after 2016 given that no property is acquired?
CRA noted that s. 13(35) provides that such expenditures incurred on capital account for the purpose of gaining or producing income from a business are deemed to be the cost of property that is goodwill, and that the definition of “property” in 248(1) has been amended to clarify that goodwill is property.