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4 May 1989 Income Tax Severed Letter 57814 F- Resource Expense of Limited Partnership Unedited CRA Tags 66.8(2)   95-7814 Current Amendments &                    Rulings Directorate   Regulations Division                  Resource Industries                                          Section B. ...

2 November 1989 Internal T.I. 58197 F- Warehousing of Resource Expenditures Unedited CRA Tags 66(12.6), 66(15) principal-business corporation, 66(15) flow-through share, 66.1(6)(a)(iv)   November 2, 1989 GAAR Committee Resource Industries   Section   Allan B. Nelson   957-8984   File No. 5-8197 Subject: Warehousing of Resource Expenditures Issue Whether GAAR would apply to deny a resource company's renunciation of resource expenditures to Its flow-through share Investors In a scenario where the sole purpose of using a particular partnership arrangement was to facilitate the resource company's warehousing of the resource expenditures until it decided if flow-through share agreements would be entered into. ... These warehousing arrangements could take various forms, for example: (i)       A limited partnership enters into flow-through share arrangements with resource companies.  ...

The royalty constitutes a Canadian resource property pursuant to subparagraph 66(15)(c)(v) of the Act, 3.      ... Thus, the payment would not be included in the computation of eligible resource profits for purposes of sections 1204 and 1210 of the Regulations.       ... Thus, the payment would reduce resource profits computed for purposes of section 1210 of the Regulations.       ...

Principal Issues: Meaning of "real property" and "mineral resource content" in definition for Canadian resource property, 66(15) of the Act. ... As the term is used in Canadian resource property, " mineral resource content" means minerals situated in the "mineral resource" as that term is defined in subsection 248(1) of the Act. ... For the purpose of paragraph (f) of the definition for Canadian resource property in subsection 66(15) of the Act, "mineral resource content" refers to the mineral resource that is situated in or derived from the real property. ...

F2959 F- Resource Industries Unedited CRA Tags 66.8(2)     October 23, 1989 Ms. ... Burnett/957-2078 Resource Industries Division   File No. F-2959 Subsection 66.8(2) of the Income Tax Act This is in response to the memorandum of May 5, 1989 prepared by F. ...

21 June 2021 External T.I. 2021-0892971E5- Mineral Resource- Gold and Gravel Deposits Unedited CRA Tags Definition of "mineral resource" in subsection 248(1) Principal Issues: Whether the gold deposit and the gravel deposit on the property fall within the definition of "mineral resource" in subsection 248(1). Position: The gold deposit is a mineral resource but the gravel deposit is not. ... “Mineral resource” is defined in subsection 248(1) of the Act as follows: “ mineral resource” means (a) a base or precious metal deposit, (b) a coal deposit, (c) a bituminous sands deposit or oil shale deposit, or (d) a mineral deposit in respect of which (i) the Minister of Natural Resources has certified that the principal mineral extracted is an industrial mineral contained in a non-bedded deposit, (ii) the principal mineral extracted is ammonite gemstone, calcium chloride, diamond, gypsum, halite, kaolin or sylvite, or (iii) the principal mineral extracted is silica that is extracted from sandstone or quartzite Since gold is a precious metal, the gold deposit on the Property qualifies as a “mineral resource” under paragraph (a) of that definition and no certification is required. ...

If the taxpayer decides not to claim the paragraph 20(1)(m) reserve, is the income that is included under paragraph 12(1)(a) considered to be resource income eligible for the resource allowances deduction? ... Once delivery has been made, there is no reserve, and the entire previous year's reserve would be income eligible for the resource allowance. ... Chief Resource Industries Section Bilingual Services & Resource Industries Division Rulings Directorate c. c. ...

9 May 1990 Income Tax Severed Letter 900480- Sources of income and Resource Profits TO S.G. ... If the taxpayer decides not to claim the paragraph 20(1)(m) reserve, is the income that is included under paragraph 12(1)(a) considered to be resource income eligible for the resource allowances deduction? ... Chief Resource Industries Section Bilingual Services & Resource Industries Division Rulings Directorate c.c. ...

16 October 1990 External T.I. 9014515 F- Resource Industries- Prescribed Share Excluded from Meaning of Flow-through Share Unedited CRA Tags 66(15) flow-through share, 66(15) selling instrument, 66(15) principal-business corporation, ITR 6202.1(1), 6202.1(5) 24(1) Resource Industries   Section   Allan Nelson   (613) 957-8984   5-901451 19(1) October 16, 1990 Dear Sirs: Re:  Paragraph 6202.1(1)(d) of the Regulations to The Income Tax Act We are writing in response to your letter of June 20, 1990, wherein you requested our views concerning the application of paragraph 6202.1(1)(d) of the Regulations to the Income Tax Act ("Regulation 6202.1(1)(d)"). ... Drillco say also joint venture with Oilco. 4.     The selling instrument indicates as follows: (a)     that investment in the shares is highly speculative; (b)     that no market exists for the shares and that it may be difficult or even impossible for a subscriber to sell his securities.       ... Yours truly, ChiefResource Industries SectionBilingual Services & Resource Industries Division ...

19 November 1990 Internal T.I. 9030467 F- Hedging Gains Resource Allowance Unedited CRA Tags n/a   November 19, 1990 E.H. ... Shaw   957-8968 Attention: S. Lakhani   7-903046 SUBJECT:  Hedging gains Resource Allowance This is in reply to your memorandum of October 29, 1990 in which you requested our confirmation that Brian Dawe's July 8, 1983 memorandum setting out an "administrative position" that hedging gains and losses would be taken into account in computing resource profits for the purposes of the resource allowance deduction where the hedge is satisfied by a delivery of the hedger's production was, and remains, in accordance with our views of the law. ... HMQ 84 DTC 6535-     Gunnar Mining Limited v. MNR 68 DTC 5035-     Guthrie v. ...