Is a future income tax asset an asset used in an active business for the purposes of the definition of qualified small business corporation share in s. 110.6(1) and of small business corporation in s. 248(1)? CRA responded (reversing 2000-001582 and 2008-028530):
[A[ future income tax asset is not an asset for the purposes of the definition of QSBCS and the definition of SBC. …
Furthermore, where a future income tax asset becomes a tax receivable, this tax must be considered as an asset in determining whether a share is a QSBCS or if a corporation is a SBC. The tax receivable may be an asset used in the active carrying on of a business for [such] purposes … . For example … tax receivable due to the carryback of a loss from an active business is an asset used primarily in the business that the corporation is actively carrying on for purposes of both definitions. …
The same interpretation applies to deferred tax assets.