After indicating that even though taking deductions under s. 66.7(3) to (5) from successored resource pools against income from successored properties can have the effect of preserving all or part of a current year’s loss from another business, such deductions cannot create or increase a taxpayer’s non-capital loss, the Directorate went on to state:
In particular, successored resource expenses cannot be deducted in computing the income or loss of a taxpayer from a business or property by virtue of the restriction in paragraph 18(1)(a) which, among other things, limits deductions in computing income from a business or property to outlays or expenses made or incurred by the taxpayer. Successored resource expenses under section 66.7 are, by their nature, not outlays or expenses made or incurred by the taxpayer that is seeking to deduct them, being the successor. Instead, successored deductions are with respect to outlays or expenses that were made or incurred by an original owner of the successored property.