Search - ”资源化利用" resource

7 March 1991 Income Tax Severed Letter- Saskatchewan Capital Tax- Resource Surcharge Unedited CRA Tags 18(1)(m) Re: Audit Policy TITLE: Saskatchewan Capital Tax- Resource Surcharge LEGISLATION: Sec. 16(1)(m) ISSUE: Is the "Saskatchewan Resource Surcharge" a non deductible amount in accordance with paragraph 18(1)(m) of the Act? ... The resource surcharge is computed by reference to the value of the corporation's Saskatchewan resource sales (production), and as part of a Provincial tax levy is thus a non deductible amount. Resource Sales are defined in the Saskatchewan legislation as the wellhead value of certain oil & gas production and the mine-gate, or equivalent, value of uranium, coal and potash production. ...

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 Deposit located on the Property. ... Yours truly, Kimberley Wharram Manager Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch Appendix A – Mining Claims List XXXXXXXXXX ...

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 Deposit located on the Property. ... Yours truly, Kimberley Wharram Manager Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch Appendix A – XXXXXXXXXX ...

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 Deposit located on the Property. ... Yours truly, Kimberley Wharram Manager Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch Appendix A – XXXXXXXXXX ...

15 April 2025 External T.I. 2024-1021011E5- Mineral Resource Certification 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 spodumene deposits will be a principal mineral extracted from a non-bedded deposit. ... We obtained an opinion from the Minister of Natural Resources (“NRCan”) regarding the Deposit located on the Property. ... Yours truly, Kimberley Wharram Manager Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch Appendix A – Mining Claims List XXXXXXXXXX ...

8 February 1980 Income Tax Severed Letter 5-1787- [Inventory Resources- Automobile Dealers] February 8, 1980 HEAD OFFICE Corporate Rulings Directorate K.J. Donnelly Inventory Resources- Automobile Dealers This is in reply to your memorandum of January 15, 1990 requesting our opinion as to whether a particular automobile dealer is permitted, for tax purposes, to reduce his inventory values to wholesale or replacement values. ... Chief Services, Public Utilities, & Exempt Corporation Section Corporate Rulings Division Corporate Rulings Directorate Legislation Branch ...

Does the existence of undeducted resource pools have an impact upon the determination of the cost amount of a Canadian resource property? ... It is our view that the "cost amount" of a Canadian resource property is nil. ... The question and answer was reviewed by John Kurrant, Oil & Gas Specialist on June 12 and he said that he does not have any concerns. ...

Does the existence of undeducted resource pools have an impact upon the determination of the cost amount of a Canadian resource property? ... It is our view that the "cost amount" of a Canadian resource property is nil. ... The question and answer was reviewed by John Kurrant, Oil & Gas Specialist on June 12 and he said that he does not have any concerns. ...

Principal Issues: section 43.1, Canadian resource property Position: 43.1 does not apply to disposition of life interest in Canadian resource property Reasons: scheme of Act, wording of 43.1 XXXXXXXXXX 980531 Denise Dalphy Attention: XXXXXXXXXX June 24, 1998 Dear Sirs: Re: Interests in Mineral Rights This is in reply to your letter dated February 25, 1998 concerning the disposition of an interest in mineral rights. ... While subsection 43.1(1) of the Income Tax Act (the “ Act”) begins with the words “Notwithstanding any other provision of the Act”, it does not provide that its deemed disposition rule with respect to the life estate retained applies for all purposes of the Act. In our view, the section 43.1 deeming provisions do not extend to the computation of proceeds of disposition of a “Canadian resource property”. ...

M.N.R. 49 DTC 602 and Dominion Steel & Coal Corp. Ltd. v. M.N.R. 57 DTC 147- but do not consider either decision of much assistance in resolving the matter, at least beyond their assistance in removing any minor doubt that such hedging gains on hedging arrangements were on income account or were on account of capital. ... In Cominco, business interruption insurance was found not to be "production profits" or 'resource profits". ... Yours truly, Chief Resource Industries Section Rulings Directorate ...