F 4081
Subsection 37(2) and Subparagraph 37(7)(c)(i) of the Income Tax Act
This is in response to the memorandum of February 4, 1991, prepared by F. Fontaine concerning the above provisions of the Income Tax Act.
We agree that, since subsection 37(2) of the Act only applies to expenditures of a current nature, the words "of a current nature" in clause 37(7)(c)(i)(B) are redundant. However, we do not believe there is any lack of clarity since subsection 37(2) of the Act is the provision under which the allowable deduction would be determined and the provision restricts the deduction to expenditures of a current nature only.
21(1(b)
R.G. D'Aurelio Director Current Amendments and Regulations Division