Principal Issues: Whether, in computing the "equity amount" under subsection 18(5) of the Act, a taxpayer should include the original acquisition cost in respect of eligible capital property or the "cost amount" within the meaning assigned by subsection 248(1) of the Act.
Position: The original acquisition cost of eligible capital property should be taken into account in computing the "equity amount".
Reasons: Interpretation of the definition of "equity amount" in subsection 18(5) of the Act and CRA's prior position.