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., to expose steeply-dipping mineralization) and digging test pits (for shallow mineralization) Definition or infill drilling, Resource estimation and deposit delineation, deposit modelling and updating resource estimates Testing of rock stability, of mineral resource dilution (re waste rock) and of metallurgy (re difficulty of separating pay material) including grinding tests Metallurgical separation testing on core or bulk samples (to determine recoverable percentage of minerals) – but not if for determining an optimal method of separation Bulk sampling (in reasonable sizes) for determining the effective grade (after dilution), performing grinding tests and whether any separation process (e.g. flotation or solvent extraction) allows minimum quality specifications- provided it is not for determining the optimal processing method Note: various of the above items do not qualify as CEE if they are performed for camp, infrastructure or mine design purposes. ... (f) potentially may include activities engaged in after the feasibility study preparation “to increase the level of geological knowledge and confidence in the mineral resource.” ... The following are deductible under s. 9 if incurred before making a decision to bring the mine into production (otherwise generally Class 41 or 41.2 assets or other depreciable property, or Class 14.1 if the property is not acquired – or CDE under para. ...

10 October 2006 Internal T.I. 2006-0169051I7- Successor Pool Issues-- summary under Subsection 66.7(5) Summary Under Tax Topics- Income Tax Act- Section 66.7- Subsection 66.7(5) Given that the successor provisions concern income attributable to " production from the particular property", rather than income attributable to the "particular property", a taxpayer may deduct its successored resource pools against income from a particular successor property (e.g., a lease) that has only arisen as a result of development of the property after the successoring of the resource pools, even though the further development could itself be regarded as giving rise to a new form of Canadian resource property (the oil or gas well). ...

Treaty provides that a permanent establishment exists in a Contracting State if the use of an installation or drilling rig or ship in that State to explore for or exploit natural resources is for more than three months in any twelve-month period. ... Accordingly … “three months” generally means the aggregation of the number of days in three months. ... Treaty includes preparation time, it stated: During preparation time, the installation or drilling rig or ship in question is in the process of getting ready to operate and is not yet capable of being utilized to explore for or exploit natural resources. ...

7 June 2017 CPTS Roundtable, 2017-0695131C6-- summary under Proceeds of Disposition Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Proceeds of Disposition Q.1- Daishowa extends beyond reforestation and reclamation obligations only on a case-by-case basis The 2014 Alberta CPA Roundtable, Q,1 indicated that the Daishowa principle applied to the resource industry. ... The SCC also implied, in obiter dicta, that its decision could apply to reclamation obligations in the mining and oil and gas industries. … … It is CRA’s position that reforestation obligations in the forest industry and reclamation obligations in the mining and oil and gas industries are generally embedded in the related tenures or rights, as they cannot usually be severed and would therefore depress the value. Furthermore, the CRA’s position does not generally extend to sales transactions outside the resource industries but we are willing to consider fact situations on a case by case basis. ...

24 May 2005 External T.I. 2005-0121291E5 F- Processing in Canada of ore-- summary under Clause Subparagraph 1204(1)(b)(iii)(A) Summary Under Tax Topics- Income Tax Regulations- Regulation 1204- Subsection 1204(1)- Paragraph 1204(1)(b)- Subparagraph 1204(1)(b)(iii)- Clause Subparagraph 1204(1)(b)(iii)(A) second crushing of nickel ore at the surface generated gross resource profits Mineco crushes nickel ore underground in its mine. ... CRA stated: [T]he revenues that Opco would earn in a particular year from the Second Crushing activity could be included in computing its GRP for that year under clause 1204(1)(b)(iii)(A) … since they could constitute revenues for the year from the processing in Canada of ore derived from mineral resources in Canada that would not be mined by Opco to any stage that is not beyond the prime metal stage or its equivalent. ...

11 August 2020 Internal T.I. 2018-0782181I7- Successored CCEE and Non-Capital Losses-- summary under Subsection 66.7(3) Summary Under Tax Topics- Income Tax Act- Section 66.7- Subsection 66.7(3) deductions of successored resource expenditures cannot generate a non-capital loss Can a principal-business corporation create or increase a non-capital loss with a deduction for successored cumulative Canadian exploration expense (“CCEE”) under s. 66.7(3)? ... This is in contrast to a subsection 66.1(2) deduction … [which] cannot result in the preservation (or creation or increase) of a non-capital loss. … [E]ven though deductions under subsection 66.7(3) (as well as under subsections 66.7(4) and (5)) might effectively preserve all or part of a current year loss as discussed above, they cannot, in and of themselves, create or increase a taxpayer’s non-capital loss. ... For taxation years ending after 2020, the CRA’s assessing practice will take into account the above position for all types of successored resource pools. ...

In our view, this resource constitutes a relief provided by the State to people in need because of their state of health. ... [A]mounts paid when a space reserved by the public facility is not occupied by a user … are paid based on a review of the users' needs because the amount is calculated based on what the users would have needed if they had occupied the spaces. As regards the contribution of users … it could also constitute a social assistance benefit …. ...

However, a resource may receive may also receive an amount directly from the user. The Directorate stated: If an Individual receives an amount directly from a resource user, that amount will be excluded from the Individual's income only if the Individual can demonstrate that the amount received is a social assistance benefit received indirectly by the Individual under a federally or provincially legislated program, based on a means, needs and income test. ... For the purposes of subparagraph 81(1)(h)(i), we are of the view that the children's special allowance [so] paid … is not an amount of family allowance under the LAF and the payment of such an allowance would not preclude the exemption from the social assistance benefit that would otherwise qualify pursuant to paragraph 81(1)(h). ...

21 May 2014 External T.I. 2014-0528021E5- Classification of Timber Limits-- summary under Schedule VI Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule VI timber limit v. timber resource property Standing timber is harvested and the land is subsequently disposed of at a gain. CRA stated: Generally a right not categorized as a "timber resource property" will be a timber limit. ... Timber limits usually include, among others, the right to cut which arises from the ownership of private land with timber. … [T]he cost of land with standing timber characterized as a timber limit would be more appropriately included in Schedule VI rather than under Class 15 of Schedule IV…. ...

1 March 2016 Internal T.I. 2016-0631181I7- Specified foreign property- mineral rights-- summary under Specified Foreign Property Summary Under Tax Topics- Income Tax Act- Section 233.3- Subsection 233.3(1)- Specified Foreign Property mineral right is real property which is intangible property After noting that 2014-0522241I7 indicated that a right to mine for minerals in a mineral resource outside Canada falls within s. (b)(ii) of “foreign resource property” in s. 248(1), that “for such mineral right to be considered specified foreign property, the right would have to be tangible property, which is understood to include real property such as land and rights issuing out of, annexed to and exercisable within or about land,” and that the mineral right would be considered a tangible property coming within s. (b) of 233.3(1) – “specified foreign property,” CRA stated: We wish to clarify that a specified foreign property can include inter alia tangible or intangible property…., real property can include… intangible property…[and] a mineral right would likely be considered an intangible property. ...