The CRA takes the position that a future income tax asset it not an asset for the purposes of the QSBCS and SBC definitions. Such an asset should be ignored when determining whether a share is a QSBCS or a corporation is an SBC. A future income tax asset that becomes a receivable is relevant to these definitions per Munich Reinsurance Company (Canada Branch) v R, 2000 CanLII 308 (TCC). See TI 2014-0537611C6, dated October 11, 2013, and summarized in Mylène Tremblay, “Is a Future Income Tax Asset an Asset Used in an Active Business?” Canadian Tax Focus 4:4 (November 2014).
