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16 May 1983 Income Tax Severed Letter 7-2462- [Part XII of the Income Tax Regulations ("ITR") — Royalty Trusts — Reporting of resource income and allowances] DATE: May 16, 1983 TO- COMPLIANCE DIRECTORATE Audit Programs Division FROM- CORPORATE RULINGS DIRECTORATE J.C. ... McDonald Estate and Trust Group RE: Part XII of the Income Tax Regulations ("ITR") Royalty Trusts Reporting of resource income and allowances A correction is required to our memorandum of April 29, 1983, a copy of which is attached. ... Chief Mines, Oil & Forest Industries Section Specialty Corporations Rulings Division Corporate Rulings Directorate Legislation Branch Attachment ...

28 November 1989 External T.I. 58940 F- Diamond Deposits — Mineral Resource Unedited CRA Tags 248(1) mineral resource 19(1) File No. 5-8940   G.R. White   (613) 957-8585 November 28, 1989 Dear Sirs: Re:  Diamond Deposits- Mineral Resource We are writing in reply to your letter dated October 19, 1989, in which you requested certification that any diamond deposits discovered in kimberlite pipes as a result of the 24(1) would qualify as a mineral resource as defined in subsection 248(1) of the Income Tax Act (the "Act"). ... Yours truly, Section Chief Resource Industries SectionBilingual Services and Resource Industries DivisionRulings Directorate ...

28 November 1989 Income Tax Severed Letter AC58940- Diamond Deposits — Mineral Resource November 28, 1989 Dear Sirs: Re: Diamond Deposits- Mineral Resource We are writing in reply to your letter dated October 19, 1989, in which you requested certification that any diamond deposits discovered in kimberlite pipes as a result of the 24(1) would qualify as a mineral resource as defined in subsection 248(1) of the Income Tax Act (the "Act"). ... Consequently, we are of the opinion that the diamond deposits would qualify as a mineral resource under subparagraph (d)(i) of the definition in subsection 248(1) of the Act. Yours truly, Section Chief Resource Industries Section Bilingual Services and Resource Industries Division Rulings Directorate ...

18 March 1983 Income Tax Severed Letter 5-0057- [(1) Gross & Net Royalty Trust/(2) Reporting of Resource Income and Allowances] DATE: March 18, 1983 TO- Corporate Rulings Division FROM- Audit Programs Division Estate and Trust Group T. ... Carsley RE: (1) Gross & Net Royalty Trust (2) Reporting of Resource Income and Allowances We refer to the attached memoranda at March 8 and 15 concerning resource income and resource allowance. ...

16 May 2023 External T.I. 2023-0967461E5- 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. ... Definition of Mineral Resource In order for subparagraph (d)(i) of the definition of “mineral resource” in subsection 248(1) of the Act to apply, three conditions must be met: 1. a principal mineral must be extracted, 2. that mineral is an industrial mineral; and 3. that mineral is contained in a non-bedded deposit. We obtained an opinion from the Minister of Natural Resources (“NRCan”) regarding the Deposits located on the Property. ...

1 September 1992 Income Tax Severed Letter 9225591- Finished Goods in the Resource Industries ITC/M & P Unedited CRA Tags 127(11)(b)(i), 125.1(3)(b), Reg. 5202 REVENUE CANADA FORESTRY TAX CONFERENCE PRESENTATION BY RULINGS "FINISHED GOODS" FOR ITC AND M&P PURPOSES After a detailed study conducted during 1991, supported by a written opinion from the Department of Justice ("Justice"), Rulings adopted the view that the products of the extractive industries, such as the logs (the felled trees) from logging, would not constitute "finished goods" referred to in subparagraph 127(11)(b)(i) of the Income Tax Act and paragraph (d) of the definition of "qualified activities" in section 5202 of the Income Tax Regulations for purposes of determining a taxpayer's investment tax credits ("ITC") and manufacturing and processing ("M&P") profits. ... Prepared by:John Chan Date: September 1, 1992 File #: 7-922559 Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information ...

16 August 2000 External T.I. 2000-0031305- Gross Resource Profits & Gas/Oil well equi, Unedited CRA Tags 1104(2) 1204(1)(b) 1204(3) 248(1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Pursuant to paragraph 1204(1)(b) of the Regulations, "gross resource profits" of a taxpayer include the amount, if any, of the aggregate of his incomes from (i) the production of petroleum, natural gas, related hydrocarbons or sulphur from (A) oil or gas wells in Canada operated by the taxpayer, or (B) natural accumulations (other than mineral resources) of petroleum or natural gas in Canada operated by the taxpayer... ... Yours truly, John Chan, CA Manager Resource Industries Section Resources, Partnerships and Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch?? ...

13 August 1992 External T.I. 9207735 F- Resource Royalty Payments- Resource Profits Unedited CRA Tags 66(15) Canadian resource property, ITR 1206(9), ITR 1210(1)(a)(i)(a), ITR 1204(1)(b), ITR 1204(1)(b.1) 24(1) 920773   John Chan   (613) 957-8975 Attention:  19(1) Dear Sirs: Re:  Resource Royalty Payments This is in reply to your letter dated March 12, 1992 wherein you requested a technical interpretation in connection with the application of certain provisions of the Income Tax Act (the "Act") and the Income Tax Regulations (the "Regulations") to resource royalty payments in the context of a hypothetical fact situation.  ... the production revenue from the CRP would be included in the computation of Corporation A's income for purposes of the Act and in the calculation of Corporation A's resource profits under paragraph 1204(1)(b) of the Regulations; 2.      ... the GOR paid by Corporation A would not reduce Corporation A's resource profits in computing its resource allowance under clause 1210(1)(a)(i)(A) of the Regulations; and 4.      ...

26 October 1989 Internal T.I. 58899 F- "Mineral Resource"- Subsection 248(1) Unedited CRA Tags 248(1) mineral resource Director General   Tax Policy Analysis Division File No. 5-8899 Energy Mines & Resources Canada G.R. ... Schell Director Mining Tax Legislation Interpretation Division October 26, 1989 Dear Sirs: Re:  24(1) Mineral Resource Subsection 248(1) of the Income Tax Act We are writing to request your certification that the 24(1) 24(1) is a mineral resource as that term is defined under subparagraph (d)(i) of the definition in subsection 248(1) of the Income Tax Act. ...

19 October 1989 External T.I. 58850 F- "Mineral Resource"- Subsection 248(1) Unedited CRA Tags 248(1) mineral resource Director General Tax Policy Analysis Division Energy, Mines & Resources Canada File No. 5-8850 Room 706, 580 Booth Street G.R. ... Shell DirectorMining Tax Legislation Interpretation Division October 19, 1989 Dear Sirs: Re:  24(1) Mineral Resource Subsection 248(1) of the Income Tax Act We are writing to request your certification that diamond deposits occurring in kimberlite pipes is a mineral resource as that term is defined under subparagraph (d)(i) of the definition in subsection 248(1) of the Income Tax Act. ...