27 November 2018 CTF Roundtable Q. 15, 2018-0780011C6 - Class 14.1 -- summary under Class 14.1

Class 14.1 depreciable property references “property” of the taxpayer. CRA confirmed that this does not have the effect of disqualifying capital expenditures that did not give rise to property rights (such as legal costs of an aborted acquisition , see 2017-0727041E5). The reason is that s. 13(35) provides that such expenditures incurred for the purpose of gaining or producing income from a business are deemed to be the cost of property that is goodwill, and the s. 248(1) definition of “property” has been amended to clarify that goodwill is property.