Income Tax Severed Letters - 2024-08-21

Ruling

2022 Ruling 2021-0910431R3 - Loss consolidation arrangement

Unedited CRA Tags
20(1)(c), 55(2)
loss-consolidation transaction which avoided loans to the regulated Profitcos through the use of a partnership
s. 112(1) deduction to partners on dividend income component of income allocation to them by limited partnership

Principal Issues: Whether the LCA is acceptable.

Position: Yes.

Reasons: The proposed transactions fall within CRA's policy position.

Technical Interpretation - External

19 July 2023 External T.I. 2023-0970581E5 - Mineral Resource Cert - XXXXXXXXXX Project

Unedited CRA Tags
Definition of "mineral resource" in subsection 248(1)

Principal Issues: Whether NRCan can certify that the principal mineral to be extracted from the lithium-bearing silicate spodumene deposits of the taxpayer will be a principal mineral extracted from a non-bedded deposit.

Position: Yes.

Reasons: Positive Opinion provided by NRCan.

27 June 2022 External T.I. 2022-0935291E5 - Mineral Resource Cert - XXXXXXXXXX

Unedited CRA Tags
Definition of "mineral resource" in subsection 248(1)

Principal Issues: Whether NRCan can certify that the principal mineral to be extracted from the silica quartz deposit of the taxpayer will be an industrial mineral extracted from a non-bedded deposit.

Position: No, but the deposit should qualify under (d)(iii) of the definition of mineral resource.

Reasons: Positive Opinion provided by NRCan that the principal mineral that will be extracted from the quartzite deposit is silica (which is synonymous with silica quartz). Therefore, the quartzite deposit should qualify as a mineral resource under subparagraph (d)(iii) of the definition of that term.