Principal Issues: Question 4: Will the CRA's treatment of farmouts, as expressed in IT-125R4, par. 14, be extended to transactions where the farmor grants a royalty to the farmee?
Position: Generally, maintain the administrative treatment set forth in IT-125R4, par. 14.
Reasons: In light of the variety of interests that could be granted as consideration for the farmee's undertakings, it is appropriate to consider any particular interest that is to be granted in the context of an individual advance income tax ruling application and according to the historical basis for the administrative treatment.