20 April 1990 TI 5-9269

A taxpayer (which is not a principal business corporation) may deduct CEE or CDE without restriction to its income so as to create a non-capital loss provided that the deduction under s. 66.1(3) or 66.2(2) is referable to a source that is business or property. If the deductions for CEE and CDE are not attributable to a particular source the amount may be claimed as a deduction under s. 3(d) but a non-capital loss cannot be created.

A taxpayer (which is not a principal business corporation) may deduct CEE or CDE without restriction to its income so as to create a non-capital loss provided that the deduction under s. 66.1(3) or 66.2(2) is referable to a source that is business or property. For purposes of s. 3(a), flow-through shares constitute a source.