84 C.R. - Q.41

The cost of a "warehouser" in making an SRTC issue is deductible from the gain realized in purchasing an SRTC security.

On an SRTC "quick flip", assuming $100 was borrowed and $55 received on redemption and used for the purpose of earning income from business or property, interest only on the $55 will be deductible.

An expenditure generally is "made" when it is "incurred", i.e., the accrual basis applies.

Those who as a result of a course of conduct have a pattern of buying and selling may be precluded from electing.

The gain to an investor/purchaser on "quick flip" (SRTC) investments is income.

Notwithstanding the "wholly attributable" requirement, where a specific area within a building is set aside exclusively for R&D for the foreseeable future, RC will allow a reasonable proportion of the cost of the building.

Generally, "all or substantially all" means at least 90%.