Search - ”资源化利用" resource

Results 1 - 10 of 8790 for ”资源化利用" resource

Resource Capital – Australian Federal Court of Appeal finds that, in determining whether the principal asset of a mining company is resource property, substantial separate value should not be accorded to the (intangible) mining information

4 April 2014- 10:41am Resource Capital – Australian Federal Court of Appeal finds that, in determining whether the principal asset of a mining company is resource property, substantial separate value should not be accorded to the (intangible) mining information Email this Content A year ago, the Australian Federal Court found that if a sale of shares by a non-resident vendor (RCF) of an Australian gold mining company had not been Treaty-exempt, the company should not be considered to have more than 50% of its assets as Australian real property (i.e., its mining rights), so that the gain also would not have been taxable under the Australian equivalent of the taxable Canadian property rules. ... Resource Capital Fund III LP, [2014] FCAFC 37 (Fed. Ct. of Austr.) under General Concepts – fair market value – other and Treaties – Art 4. ...

S3-F8-C1 - Principal-business Corporations in the Resource Industries -- summary under Principal-Business Corporation

S3-F8-C1- Principal-business Corporations in the Resource Industries-- summary under Principal-Business Corporation Summary Under Tax Topics- Income Tax Act- Section 66- Subsection 66(15)- Principal-Business Corporation Meaning of petroleum products in s. 66(15)(a) 1.4 …[P]etroleum products…in paragraph (a) of the PBC definition, includes all steps up to the production and sale of a petroleum product as a raw material…. ... Meaning of Fabrication of Metals (s. 66(15)(e)) 1.7 Paragraph (e) of the PBC definition includes operations such as the manufacture of alloys (for example, brass, solder, and stainless steel) and the intermediate or final stages of manufacturing metals such as stamping, forming, machining, welding, cutting, or casting. … Comparison of resource and non-resource activities 1.11 A…corporation will generally qualify as a PBC if the corporation's activities of the kind described in [s. 66(15)] represent a larger or more important business operation than all other activities of the corporation combined…. 1.12 The following are important criteria for making [this] determination…: the amount of income derived from each business operation; the amount of gross revenue attributable to each business operation; the operating costs and expenses of each business operation; the capital employed in each business operation; and the time and effort expended by the employees on each business operation. ... For example, a mining corporation which has qualified as a PBC for many years might suffer a temporary decline in its mining activity in a particular year due to various problems, such as adverse economic conditions, labour problems, or other short-term difficulties. … [I]n determining whether a corporation qualifies as a PBC for a particular year, regard may be had to a future plan of the corporation to the extent that it is implemented in the year. ...

Brilliant Resources -- summary under Ss. 84(4.1)(a) and (b) distributions of proceeds

Brilliant Resources-- summary under Ss. 84(4.1)(a) and (b) distributions of proceeds Summary Under Tax Topics- Public Transactions- Spin-Offs & Distributions- Ss. 84(4.1)(a) and (b) distributions of proceeds Stated capital distribution by Brilliant Resources of cash expropriation proceeds in reliance on s. 84(4.1) Return of Capital The stated capital account maintained by the Corporation in respect of its Common Shares will be reduced by an amount equal to $0.145 multiplied by the number of Common Shares issued and outstanding as at the Return of Capital Record Date. ... The Subsidiary Ivory Resources Inc., a Caymans company which formerly engaged in exploration in Equatorial Guinea. ...

Dare Human Resources – Ontario Court of Appeal finds that placement agencies were the workers’ employers

15 January 2020- 11:32pm Dare Human Resources – Ontario Court of Appeal finds that placement agencies were the workers’ employers Email this Content Two Ottawa placement agencies supplied temporary workers to the Public Service of Canada and federal agencies. ... Summary of Dare Human Resources Corporation v. Ontario (Revenue), 2019 ONCA 549 under Reg. 100(1) – employer. ...

7 January 2013 External T.I. 2012-0460791E5 - Qualified Farm Property & Oil Reserves -- summary under Canadian Resource Property

7 January 2013 External T.I. 2012-0460791E5- Qualified Farm Property & Oil Reserves-- summary under Canadian Resource Property Summary Under Tax Topics- Income Tax Act- Section 66- Subsection 66(15)- Canadian Resource Property In response to a question "as to whether a taxpayer whose farm property meets the definition as a "qualified farm property"... within the meaning of subsection 110.6(1)...will be eligible to claim the capital gains deduction under subsection 110.6(2) on a subsequent disposition of the farm property in circumstances where petroleum or natural gas reserves are discovered on the property," CRA responded: any real property the principal value of which depends on its petroleum, natural gas or related hydrocarbon content will constitute a "Canadian resource property"....For these purposes "principal" means more than 50%. Where the taxpayer owns one right that includes both the surface right and the subsurface right, and more than 50% of the value of the real property depends on the petroleum or natural gas reserves, the right would constitute a Canadian resource property and the disposition of the right would result in the tax consequences described in the previous paragraph [i.e., income inclusion under ss. 66.2(1) and 59(3.2)(c), if a negative CCDE balance arises]. ...

Marret Resource -- summary under Liquidity Program

Marret Resource-- summary under Liquidity Program Summary Under Tax Topics- Public Transactions- Other- Liquidity Program Marret Resource Corp. addition of annual redemption feature to its common shares Overview The Corporation's articles will be amended to provide for the creation of unlisted Class A Shares and for an annual liquidity right (ALR), i.e., an annual offer to redeem at a discount to NAV, in respect of both the Common Shares and Class A Shares (collectively, "Shares"). ... Its business is to lend to companies in the resource sector. Its reported issued share capital appears to be higher than its market cap. ... No more than 25% of the outstanding Shares of each class may be redeemed by March 31, 2015 – and thereafter, no more than 10% annually. ...

Burlington Resources – B.C. Court of Appeal finds that cement provided to a well was part of an oil well service rather than being a sale of property for PST purposes

7 September 2015- 1:50am Burlington Resources – B.C. Court of Appeal finds that cement provided to a well was part of an oil well service rather than being a sale of property for PST purposes Email this Content Burlington Resources was found not to be the purchaser for BC provincial sales tax purposes of cement which was inserted into the well casings of wells drilled for it, on the basis that the cement had become real property by the time title to the materials passed to it. ... Burlington Resources Canada Ltd., 2015 BCCA 19 under Provincial Sales Tax Act (B.C.), s. 1 – purchaser (h/t Robert G. ...

Resource Capital Fund – Australian Federal Court decision respects the flow-through character of a reverse hybrid

4 May 2013- 9:23pm Resource Capital Fund – Australian Federal Court decision respects the flow-through character of a reverse hybrid Email this Content A Caymans LP with US-resident partners, which was treated for Australian purposes as a corporation and for US purposes as fiscally transparent, was assessed on a gain under the Australian equivalent of the taxable Canadian property rules. ... Summary of Resource Capital Fund III LP v. Commissioner of Taxation, [2013] FCA 363 under Treaties – Art. 4. ...

Burlington Resources – Crown abandons its position that s. 247(2)(c) applied to reduce guarantee fees paid by a ULC to its non-resident parent

23 February 2020- 11:44pm Burlington Resources – Crown abandons its position that s. 247(2)(c) applied to reduce guarantee fees paid by a ULC to its non-resident parent Email this Content Burlington, a Nova Scotia ULC, borrowed approximately U.S.$3 billion in 2001 and 2002 by issuing notes that were guaranteed by its non-resident parent (“BRI”). ... Summary of Burlington Resources Finance Company v. The Queen, 2020 TCC 32 under Rule 132. ...

Burlington Resources Finance – Tax Court of Canada states that taking discovery questions “under advisement” should stop

17 August 2017- 8:23am Burlington Resources Finance – Tax Court of Canada states that taking discovery questions “under advisement” should stop Email this Content CRA disallowed, in full, under s. 247(2)(a), the deduction by Burlington of guarantee fees paid to its U.S. parent. ... Summary of Burlington Resources Finance Company v. The Queen, 2017 TCC 144 under Tax Court of Canada Rules (General Procedure), s. 95(2), s. 107(1). ...

You are here