Income Tax Severed Letters - 2017-09-27

Ruling

2017 Ruling 2016-0635341R3 - Canadian Exploration Expenses - New Mine

Unedited CRA Tags
66.1(6)
Summary Under
Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (f)
drilling on an existing, currently uneconomic, mine site qualified as CEE

Principal Issues: Whether expenses relating to a proposed exploration program will not be considered to be related to a mine that has come into production in reasonable commercial quantities or to a potential or actual extension thereof.

Position: Yes

Reasons: Based on the facts presented and written opinions provided by Natural Resources Canada.

Technical Interpretation - External

15 September 2017 External T.I. 2017-0722391E5 - Investment management fees

Unedited CRA Tags
207.01(1) advantage
Summary Under
Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(1) - Advantage - Paragraph (b) - Subparagraph (b)(i)
effective date for 100% advantage tax arising where RRSP or TFSA fees are paid by the annuitant or holder is extended to 2019

Principal Issues: Announcement of deferral of implementation date for position on application of advantage tax rules to investment management fees.

Position: Deferred to January 1, 2019

Reasons: To consider submissions from stakeholders

28 July 2017 External T.I. 2017-0713031E5 - Investment account of a non-resident

Unedited CRA Tags
212

Principal Issues: What are a non-resident's tax obligations in respect of an investment account held in Canada?

Position: Withholding tax will apply to Canadian-source investment income.

Reasons: Application of section 212.

19 May 2017 External T.I. 2016-0663541E5 - Dividends received by an Indian

Unedited CRA Tags
81(1)(a)

Principal Issues: Are the dividends received by an Indian who is resident on a reserve exempt from tax?

Position: Question of fact.

Reasons: See discussion below.