Section 66.7

Table of Contents

Section 66.7
Subsection 66.7(2) - Successor of foreign exploration and development expenses
Administrative Policy(1)
Subsection 66.7(3) - Successor of Canadian exploration expense
Administrative Policy(3)
Articles(1)
Subsection 66.7(5) - Successor of Canadian oil and gas property expense
Administrative Policy(1)
Subsection 66.7(7) - Application of s. 29(25) of ITAR and ss. (1), (3), (4) and (5)
Administrative Policy(3)
Subsection 66.7(10) - Change of control
Articles(1)
Paragraph 66.7(10)(j)
Cases(1)
Administrative Policy(1)
Articles(1)
Subsection 66.7(16) - Non-successor acquisitions
Articles(2)

Subsection 66.7(2) - Successor of foreign exploration and development expenses

Administrative Policy

13 November 1991 T.I. (Tax Window, No. 13, p. 5, ¶1593)

A Canadian resource property is acquired with a foreign resource property only if they are acquired at the same time.

Subsection 66.7(3) - Successor of Canadian exploration expense

Administrative Policy

11 August 2020 Internal T.I. 2018-0782181I7 - Successored CCEE and Non-Capital Losses

Can a principal-business corporation create or increase a non-capital loss with a deduction for successored cumulative Canadian exploration...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 3 - Paragraph 3(c) s. 3(c) deduction (e.g., under s. 67.3) cannot generate a non-capital loss 92
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense successored resource expenses are not deductible under s. 9 165

94 C.P.T.J. - Q. 11

Where there is an acquisition of control of Company A thereby causing Company A's resource pools to be successored, and Company A subsequently...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

31 August 1992 Memorandum (Tax Window, No. 23, p. 16, ¶2165)

There is no requirement in s. 66.7 for the successor to have an interest in the Canadian resource property by reference to which it is taking the...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Articles

Carr, "The Successor Corporation Rules after Bill C-18", 1992 Canadian Tax Journal, No. 6, p. 1261.

Subsection 66.7(5) - Successor of Canadian oil and gas property expense

Administrative Policy

10 October 2006 Internal T.I. 2006-0169051I7 - Successor Pool Issues

Given that the successor provisions concern income attributable to "production from the particular property", rather than income attributable to...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Subsection 66.7(7) - Application of s. 29(25) of ITAR and ss. (1), (3), (4) and (5)

Administrative Policy

S4-F7-C1 - Amalgamations of Canadian Corporations

1.56 In the case of an amalgamation to which subsection 87(1.2) does not apply, any undeducted balance in a predecessor corporation's resource...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 100 - Subsection 100(2.1) s. 100(2.1) applies to non-qualifying amalgamation 64
Tax Topics - Income Tax Act - Section 111 - Subsection 111(12) application following amalgamation 113
Tax Topics - Income Tax Act - Section 116 - Subsection 116(1) deemed tcp following amalgamation 167
Tax Topics - Income Tax Act - Section 13 - Subsection 13(5.1) continuity of s. 13(5.1) on amalgamation 132
Tax Topics - Income Tax Act - Section 165 - Subsection 165(1) Amalco can continue objection and receive refunds 157
Tax Topics - Income Tax Act - Section 169 Amalco can continue objection 103
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(n) reserve after amalgamation 62
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Shareholder shareholder need not hold shares 88
Tax Topics - Income Tax Act - Section 251 - Subsection 251(3.1) deemed non-arm's length relationship on amalgamation 172
Tax Topics - Income Tax Act - Section 256 - Subsection 256(7) - Paragraph 256(7)(b) related party, majority and 50% group exceptions 495
Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(iii) reserve after amalgamation 62
Tax Topics - Income Tax Act - Section 69 - Subsection 69(13) no disposition of predecessor property on general principles 113
Tax Topics - Income Tax Act - Section 7 - Subsection 7(1.4) s. 87(5) not applicable 112
Tax Topics - Income Tax Act - Section 80.01 - Subsection 80.01(3) non-87 amalgamation/no FX gain 165
Tax Topics - Income Tax Act - Section 84 - Subsection 84(3) no deemed dividend to dissenter on amalgamation 87
Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) election filing by Amalco 109
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1.1) s. 87(1.1) qualifies for all s. 87 purposes 66
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1.2) successoring where non-wholly owned amalgamation 109
Tax Topics - Income Tax Act - Section 87 - Subsection 87(10) deemed listing of temporary Amalco shares 120
Tax Topics - Income Tax Act - Section 87 - Subsection 87(11) gain if high PUC is sub shares 55
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1) presumptive satisfaction of s. 87(1)(a)/dissent and squeeze-outs onside 297
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(a) new corp/deemed year end coinciding or not with acquisition of control 758
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(b) Amalco must follow predecessor's valuation method subject to truer picture doctrine 64
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(c) reserve after amalgamation 113
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(d) cost amount carryover 149
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(e.1) s. 100(2.1) applies to non-qualifying amalgamation 64
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(o) no continuity rule for non-security options 139
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(q) pre-amalgamation services 106
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2.11) loss-carry back to parent 169
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2.1) dovetailing with s. 88(1.1) 44
Tax Topics - Income Tax Act - Section 87 - Subsection 87(3.1) 346
Tax Topics - Income Tax Act - Section 87 - Subsection 87(3) PUC shifts 189
Tax Topics - Income Tax Act - Section 87 - Subsection 87(4) fractional share cash/ACB or value shift/implied non-recognition for predecessor shares 281
Tax Topics - Income Tax Act - Section 87 - Subsection 87(7) dovetailing with s. 78 and 112(12) 191
Tax Topics - Income Tax Act - Section 87 - Subsection 87(9) allocation of s. 87(9)(c)(ii) excess as parent chooses 230
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(d) late designation 122
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1.1) dovetailing with s. 87(2.1) 62
Tax Topics - Income Tax Act - Section 98 - Subsection 98(5) partnership dissolution on amalgamation 137
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2.2) deemed non-arm's length relationship on amalgamation 467
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) deemed non-arm's length relationship on amalgamation 371
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(14) class continuity on non-arm's length amalgamation 327
Tax Topics - Income Tax Regulations - Regulation 8503 - Subsection 8503(3) - Paragraph 8503(3)(b) pre-amalgamation services 106
Tax Topics - Income Tax Act - Section 249 - Subsection 249(3) 136
Tax Topics - Income Tax Act - Section 22 - Subsection 22(1) 179

12 June 1992 Memorandum (Tax Window, No. 21, p. 9, ¶2019)

Discussion whether the limitations in s. 66.7 apply where a corporation ("A") carrying on both a mining business and an oil and gas business and...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

90 C.P.T.J. - Q.35

Since resource pools are neither Canadian resource properties nor foreign resource properties, no value need be assigned to them for the purposes...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Subsection 66.7(10) - Change of control

Articles

Gregory M. Johnson, Wesley R. Novotny, "An Update on Flow-through Shares in the Energy Sector", 2016 Conference Report (Canadian Tax Foundation),12:1-39

Successoring rules not an issue for flow-through shares (p. 12:18)

...[S]ubsection 66.7(10) stipulates that it does not apply for the operative...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Paragraph 66.7(10)(j)

Cases

Devon Canada Corporation v. The Queen, 2013 TCC 415

Following an acquisition of control of a predecessor of the taxpayer (Home Oil), a partnership of which Home Oil was a direct member (the Anderson...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
reasonably attributable
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 102 - Subsection 102(2) source preservation in 2-tier partnership 84

Administrative Policy

15 March 2012 External T.I. 2012-0432931E5 - Partnership property of successor corporation

Where the corporation is a member of a partnership which, in turn, is a member of a lower-tier partnership, s. 66.7(1)((j) applies on the basis...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Articles

Marshall Haughey, "Tiered Partnerships: Successor Rules", Canadian Tax Highlights, Vol. 22, No. 2, February 2014, p. 13.

Creation of 2-tier partnership structure before v. after acquisition of control (p. 14)

Interestingly, if the tiered partnership structure in...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 66.7 - Subsection 66.7(16) 227

Subsection 66.7(16) - Non-successor acquisitions

Articles

Brian R. Carr, "Devon Canada Corporation v. The Queen", Resource Sector Taxation (Federated Press), Vol. IX, No. 4, 2014, p. 677.

Background to introduction of s. 66.7(1)(j) (p.678)

It has long been the position of the Canada Revenue Agency ("CRA") that a taxpayer does not...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Marshall Haughey, "Tiered Partnerships: Successor Rules", Canadian Tax Highlights, Vol. 22, No. 2, February 2014, p. 13.

Transfer of successored property to a partnership (pp. 14-5)

It is also interesting that the Crown did not argue subsection 66.7(16) [in Devon, The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Navigation