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23 January 2015 External T.I. 2013-0509771E5- Oil & gas payments made to U.S. resident-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 non-application of Art. 12 of US Treaty to resource royalties Mr. A, a U.S. resident, grants the right to drill for or take the oil & gas from his Canadian freehold property to a Canadian company, in consideration inter alia for annual royalties payable out of any oil & gas production. ...

17 June 2013 External T.I. 2013-0486901E5- Petroleum & Natural Gas Lease-- summary under F Summary Under Tax Topics- Income Tax Act- Section 66.4- Subsection 66.4(5)- F proceeds of CRP upon entering into oil and gas lease The taxpayer inherited subsurface exploration rights from his father with a deemed cost under s. 70(5.2) equal to their fair market value, and leased those rights to a corporation for a lump sum. ... Since a CRP [Canadian resource property] is defined as including any right, licence or privilege to explore for, drill for or take petroleum, natural gas or related hydrocarbons in Canada, we believe that the consideration received by the lessor for entering into such a lease should be treated as proceeds of disposition of a CRP. ...

25 January 2010 Internal T.I. 2009-0319951I7- Article 15 & definition of permanent establishment-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 PE to be determined under treaty of residence of employee rather than employer ACo is a British company that performed seismic surveys offshore Canada. ... Respecting the Norwegian and Netherlands treaties, CRA stated: Paragraph 1 of Article 21 of the Canada-Norway Treaty- Offshore Activities states that Article 21 applies notwithstanding any other provision of the treaty. … Subparagraph 5(a) of Article 21 states that…remuneration derived by an employee who is resident in Norway in respect of employment connected with the exploration or exploitation of the seabed and subsoil and their natural resources situated in Canada may be taxed in Canada, but only if the employment exceeds 30 days in any 12-month period. Therefore, if the employment exceeds 30 days, remuneration paid by BCo to employees who are resident in Norway may be taxed in Canada. … Paragraph 3 of Article 23 [of the Netherlands Treaty] provides…that "an enterprise of one of the States" will be deemed to be carrying on business in Canada through a permanent establishment if the enterprise carries on Offshore Activities in Canada for more than 30 days in any 12 month period. ...

X's estate,” CRA went on to state: [S]ubsection 70(5.2), which sets out the rules applicable where a taxpayer who owns a Canadian resource property dies in a taxation year, would not be applicable … since it is our position that Mr. X's interest in SENC would not constitute a "Canadian resource property" …. ...

28 November 2010 CTF Annual Roundtable, 2010-0384341C6- Flow-through Shares-- summary under Flow-Through Share Summary Under Tax Topics- Income Tax Act- Section 66- Subsection 66(15)- Flow-Through Share flow-through unit Respecting whether CEE can be renounced under a unit flow-through share agreement in respect of the portion of the subscription price allocated to a warrant to acquire a share that is not a flow-through share, CRA stated: CEE can be renounced only in respect of the portion of the subscription price allocated to a warrant which represents a right to acquire a share that would be a flow-through share [as] pursuant to paragraph (b) of … "flow-through share," the amount of resource expenses that may be renounced under the agreement cannot exceed the amount of consideration received by the corporation for the flow-through share or the right to acquire the flow-through share…. ...

11 July 2002 External T.I. 2002-0126795 F- RESSOURCES INTERMEDIAIRES REVENU EX-- summary under Paragraph 81(1)(h) Summary Under Tax Topics- Income Tax Act- Section 81- Subsection 81(1)- Paragraph 81(1)(h) contributions paid to a Quebec intermediate resource have been treated as means-based assistance CCRA noted: [W]e have determined in the past that a contribution paid by an institution to a family-type resource or an intermediate resource under the A ct respecting health services and social services was usually a social assistance benefit paid to an individual under a provincially legislated program, on the basis of a means, needs and income test. In addition, where a user has been referred to a family-type resource or an intermediate resource by a "public institution" under [such] Act … part of the user’s contribution may also constitute such a benefit. This would be the case, for example, for any portion of a user's contribution that comes from the guaranteed income supplement or spouse's allowance paid in accordance with the Old Age Security Act or that comes from amounts of last-resort financial assistance paid under the [Quebec] Employment Assistance Program …. ...

., physical, chemical or mechanical) characteristics of the mineral resource Regarding whether the test of incurring an expense “for the purpose of determining the existence, location, extent, or quality of a mineral resource” (the “CEE Purpose Test”) would generally include expenses for determining the economic feasibility of a deposit, such as expenses for preparing pre-feasibility or feasibility studies (including expenses for determining the cut-off grade of the deposit), market studies or studies for determining the anticipated long-term price of a mineral, based on an expansive interpretation of the word “quality,” CRA noted: “the word ‘quality’ could be capable of an interpretation that either includes the concept of commercial value or that instead focuses more narrowly on the physical or inherent aspects of a particular item having regard to the ejusdem generis rule, it was to be noted that “the first three words in the list in the CEE Purpose Test” referred to “the inherent physical characteristics of the mineral resource,” which suggested that the word the word “quality” should be similarly “limited to inherent characteristics of the mineral resource,” so that it “could encompass other inherent characteristics of the mineral resource such as its chemical composition or mechanical properties (e.g., strength or porosity).” various materials suggested that the purpose to the provision was “the search for, or discovery of, the minerals in the ground,” and that expenses related to “external factors, for example the cost of bringing a product to purchasers, including marketing and distribution costs … or to the overall assessment of economic viability through a pre-feasibility study or feasibility study, extend well beyond the focused nature of an incentive targeted at the activity of mineral exploration.” CRA concluded: [E]xpenses that qualify for CEE do not … include expenses for determining the economic viability of a mineral resource if those expenses do not relate to a determination of the natural (e.g., physical, chemical or mechanical) characteristics of the mineral resource. Such expenses are too remote to be described as expenses incurred for the purpose of determining the “quality” of a resource. ...

In finding that the remission was not available, the Directorate stated: [A] "Canadian resource property" does not constitute a TCP. A taxable capital gain from the disposition of a "Canadian resource property" is therefore not included pursuant to subparagraph 115(1)(a)(iii) …. [Furthermore] … it is highly doubtful that the Right can be considered real property …. ...

PEA The Company’s exploration on the property has focused both on expanding and upgrading existing resources related to the footprint of the old mine, as well as seeking new resources outside the known resource area. ... The results of the PEA warrant additional exploration to expand the potentially mineable resource by converting inferred resources to measured and indicated. ... Ruling Re the expenses of the proposed program qualifying under s. 66.1(6) – CEE- para. ...

7 June 2017 CPTS Roundtable, 2017-0695131C6-- summary under Paragraph (d) Summary Under Tax Topics- Income Tax Act- Section 66- Subsection 66(15)- Canadian Resource Property- Paragraph (d) Q.2- a Canadian resource royalty interest requires a right to “take production” Does the reference in para. ... CRA responded: An “interest” in the well or accumulation … requires that the payer must have a right to take production from the well or accumulation. ... Of course, the conditions in paragraph (d) of the [CRP] definition … must be met …. ...