Ressources Eastmain Inc. v. Agence du revenu du Québec, 2021 QCCQ 4379 -- summary under Paragraph (b)
as a junior exploration company’s CEO devoted "substantially all" (75%) of his time to exploration, his salary was not CEDOE
The taxpayer was a micro-cap junior exploration company devoted to two projects in northern Quebec. For the four taxation years in issue (2007 to...
Words and Phrases
substantially all| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Current expense vs. capital acquisition | annual expenditures on core sample boxes and racks were capital expenditures, whereas those on dirt berms were currently deductible | 302 |
| Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (k.1) | annual expenditures on core sample boxes and racks were excluded under para. (k.1) | 105 |
| Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (f) | geology course for an employee was necessary to exploration and resource identification | 173 |