Submitted by Anonymous (not verified) on Sun, 11/29/2015 - 02:18
exploration program on site of abandoned mine
History
A former producing mine in the Concession, which was the only workings capable of producing ore, has since been abandoned and is inactive....
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Principal Issues: 1. Whether the XXXXXXXXXX will be a mine in a mineral resource that exists on the Concession for the purposes of subparagraph (f)(vi) of the definition for "Canadian exploration expense" under subsection 66.1(6) of the Act? 2. Whether expenditures relating to a proposed new mine will qualify for inclusion for the purposes of paragraph (f) of the definition for "Canadian exploration expense" under subsection 66.1(6) the Income Tax Act?
Position: (1) No (2) Yes
Reasons: Based upon the written opinion from Natural Resources Canada.
Submitted by Anonymous (not verified) on Sun, 11/29/2015 - 02:14
Natural Resources Canada listing of project development activities
In the course of a general response to a question as to whether expenses incurred in respect of a ground-source heat pump system would qualify as...
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Principal Issues: Under what circumstances costs incurred for design and installation of ground-source heat pump can be renounced to shareholders of flow-through shares?
Submitted by narmstrong on Sat, 02/18/2017 - 01:45
change to GPS coordinates does not affect 2013-0490631E5
A change to the GPS coordinates for the wind installation described in 2013-0490631E5 did not affect that interpretation.
Principal Issues: Change to location of wind turbines
Position: Confirmation that assuming that no other changes were made to the project and, subject to the conditions, limitations, qualifications, and comments set out in original interpretation 2013-0490631E5, the interpretations provided in that document will continue to be valid.
Reasons: 2013-0490631E5 and XXXXXXXXXX confirmation that as-built coordinates meet spacing requirement
Principal Issues: 1.Where a valid waiver is provided for a particular taxation year, whether a refund may be issued if the request is made beyond the date required by paragraph 164(1)(b) of the Act. 2. Would the answer change if there is a valid waiver for the same issues the refund request is based on?
Position: 1.No.
Reasons: 1. Paragraph 164(1)(b) of the Act does not provide for a refund beyond the period within which the Minister would be allowed under subsection 152(4) to assess tax payable, regardless of whether a waiver was filed for the taxation year. The application for the refund must be made within the time frames provided by 164(1)(b). Furthermore, a waiver does not extend the time frame to request a refund. 2. Where the details of the waiver also provide for a refund as a reasonable outcome of the audit, the refund request may be considered to have been made as part of the waiver and the Minister may issue the refund.
