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28 November 1989 External T.I. 58850A F- Diamonds Deposits- Mineral Resource Unedited CRA Tags 248(1) 19(1) G.R. White   (613) 957-8585   File No. 5-8850 November 28, 1989 Dear Sirs: Re:  Diamonds Deposits- Mineral Resource We are writing in reply to your letters dated October 10 and 16, 1989, in which you requested certification that any diamond deposits discovered in kimberlite pipes as a result of an exploration program of 24(1) would qualify as a mineral resources as defined in subsection 248(1) of the Income Tax Act (the "Act"). ... Yours truly Chief Resource Industries SectionBilingual Services and Resource Industries DivisionRulings Directorate ...

7 March 1991 Income Tax Severed Letter- Saskatchewan Capital Tax- Resource Surcharge Unedited CRA Tags 18(1)(m) Subject: Industry Issue Report # 5 Saskatchewan Capital Tax- Resource Surcharge ("Resource Surcharge") We are writing in reply to your memorandum of January 16, 1991, in which you requested our confirmation that the positions relied upon by you which are reflected in report #5 are current policies of Rulings in regards to the issue of whether paragraph 18(1)(m) is applicable to Resource Surcharges. ... The sentence under the heading of "Tax Implications" should be amended to reflect the tax implications affecting both income and resource allowance. ... For both earned depletion and resource allowance purposes, the former type of tax would be deductible in computing resource profits while the later type of tax would not be. 2. ...

Company B owns a royalty interest in respect of the production from this resource property. ... He wrote at the same place "The expressions "disposed of ", "lost" or "destroyed" were dealt with in the Australian case of Hentey Howe P.T.V. ... Yours truly, Chief Resource Industries Section Bilingual Services & Resource Industries Division Rulings Directorate ...

12 June 1989 External T.I. 58170 F- Small Business Deduction and Resource Allowance Unedited CRA Tags 13(1), 25(7), 39(1)(a)(ii), 59(3.2)(c), 125(1), 129(4) aggregate investment income, 129(4.1), ITR 1204(1), 1210(1) 19(1) File No. 5-8170   Allan B. ... Subparagraph 39(1)(a)(ii) of the Act excludes gains from the sale of Canadian resource properties from capital gains treatment; and (ii)      The amount of the negative CCDE pool would be specifically excluded from being treated as income from for purposes of subparagraph 129(4)(a)(ii) of the Act, by virtue of the provisions of either paragraph 129(4.1)(b) or (c) of the Act. 2.     If in the general scenario outlined above, the sale of an oil and gas well resulted in the corporation having recaptured capital cost allowance, as defined in subsection 13(1) of the Act, it is our position that the amount of the recapture would be included in the company's computation of resource profits pursuant to subsection 1204(1) of the Regulations and would thereby be included in the calculation of the company's resource allowance provided for in subsection 1210(1) of the Regulations.       ...

8 November 1989 Income Tax Severed Letter AC73828- Integrated Sawmill & Pulpmill- M & P Deduction November 8, 1989 Carole Couin-Toussaint Rulings Directorate Director Frank Cillman Bilingual Services & Resource Industries Division 7-3828A Subject: Integrated Sawmill & Pulpmill- M & P Deduction The Special Audits Division has requested that we withdraw one of our previous opinions which states that "the transportation activity of woodchips between the sawmill and the pulpmill which occurs within an integrated operation, be included as a qualified activity within the meaning of section 5202 of the Regulations so that the capital and labour costs of transporting the chips be included in the calculation of the M & p deduction." Facts The facts which relate to that particular opinion are as follows: 24(1) The Law Subsection 125.1(1) of the Act which is the subsection authorizing the M & P deduction requires the calculation of a corporation's Canadian manufacturing and processing profits ("M & p profit") in order to determine its M & P deduction. ... Therefore, for the transportation of woodchips to be a qualified activity it must be "integrally and essentially" connected to the manufacturing and processing of pulp and paper. 21(1)(b) 24(1)24(1) 21(1)(b) 23 23 Recommendation 21(1)(a) Chief Resource Industries Section Bilingual Services and Resource Industries Division ...

8 November 1989 Ministerial Letter 73828 F- Integrated Sawmill & Pulpmill- M & P Deduction Unedited CRA Tags 5202, 125.1(1)   November 8, 1989 Carole Gouin-Toussaint Rulings Directorate Director Frank Gillman Bilingual Services & Resource Industries Division   7-3828 The Special Audits Division has requested that we withdraw one of our previous opinions which states that the "transportation activity of woodchips between the sawmill and the pulpmill which occurs within an integrated operation, be included as a qualified activity within the meaning of section 5202 of the Regulations so that the capital and labour costs of transporting the chips be included in the calculation of the M & P deduction. ... (b)      all other activities... directly in connection with manufacturing or processing... but does not include any of (d)      ... shipping... of finished goods, (e)      purchasing of raw materials... ... GauvreauChiefResource Industries SectionBilingual Services and Resource Industries Division ...

31 August 1992 Administrative Letter 9222076 F- Whether Partnership Interest Is CDN Resource Property Unedited CRA Tags 66(15) Canadian resource property, 66.1(4)(b)(ii), 66.7(3)(b)(i)   922207   John Chan   (613) 957-8975 August 31, 1992 Appeals and Referrals DivisionResource Industries SectionDon BeamishSection Chief Attention: D. ... In general terms, the first successor and second successor rules as they applied to taxation years ending before February 18, 1987 (the "old successor rules") provided for the computation of the first or second successor's deduction by reference to production from Canadian resource property in respect of which the successor had an interest; or had a right to take or remove petroleum or natural gas or a right to take or remove minerals from the Canadian resource property (hereafter referred to as the "right to take")-      see for example, subparagraphs 66.1(4)(b)(ii) and (5)(b)(ii) pertaining to the first and second successor's deduction, respectively, of successored Canadian exploration expense ("CEE"). ... Under the old successor rules, therefore, a first or second successor corporation was not permitted to claim a successor deduction with respect to income from Canadian resource properties owned by a partnership, simply because it was the partnership, not the successor corporation, that had an interest in the Canadian resource properties and the right to take. ...

11 January 1990 Internal T.I. 58577 F- Hedging Gains and Losses- Whether "Resource Profits" Unedited CRA Tags 1204(1), 1104(5) 19(1) File No. 5-8577   John Shaw   (613) 957-8968 January 11, 1990 Re:  Hedging gains and losses- whether "resource profits" and  "income from a mine", subsections 1204(1) and 1104(5) of the Regulations This is in reply to your letter of August 23, 1989, in which your requested that we again examine the matter of whether hedging gains and losses related to expected production form a mine, but with respect to hedges which will not be satisfied by delivery of such production, could constitute "resource profits" an "income from a mine" for the purposes of subsections 1204(1) and 1104(5) of the Regulations to the Income Tax Act respectively. In our view, as we stated at the 1989 Canadian Tax Foundation Round Table (a copy of the question and our response is attached), profits and losses from such hedges could not represent "resource profits" or "income from a mine'.  ... In Cominco, business interruption insurance was found not to be "production profits" or 'resource profits".   ...

ACC9235 F- Use of Spousal Trust to Transfer Taxable Canadian Property and Canadian Resource Property Unedited CRA Tags 73(1)   July 19, 1990   EACC 9235 Mr. ... If the property is taxable Canadian property or resource property, the trust may subsequently rollover the property to the taxpayer's beneficiary even if he or she resides outside Canada.  ... ShortGeneral DirectorTax Policy & Legislation Branch ...

Situation 1.     An individual ("Individual A") has given consideration under an agreement to an exploration corporation ("B Co. ... The flow-through shares which have been received from B Co. are capital property to Individual A. 2.     Individual A contributes the acquired flow-through shares to his registered retirement saving plan ("RRSP") and recognizes a capital gain on the share transfer equivalent to the then fair market value of such shares. 3.      ...