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However the cash “contingent resource payment” (or “CRP”) of U.S.$26.87 per share, was to be held under an escrow arrangement, to be repaid in full if an interim resource assessment of a Papua New Guinea natural gas project of InterOil (slated to occur in the 2nd quarter of 2017), showed a resource of less than 6.2 trillion cubic feet equivalent ("tcfe"), and with the CRP having to be repaid on a pro rata basis if the interim assessment showed a resource of between 6.2 and 10 tcfe. Following a decision of the Yukon Court of Appeal reversing approval of the Plan of Arrangement, ExxonMobil has returned with the same offer (set out in a more detailed Circular of InterOil), except that the CRP cap occurs at 11 tcfe rather than 10 tcfe – and also secured a fairness opinion from BMO to InterOil which was paid for on a fixed fee rather than contingent basis. ... Summary of InterOil Circular under Mergers & Acquisitions – Cross-Border Acquisitions – Inbound – Canadian Buyco. ...

In addition to the more obvious early-stage activities, CRA also includes, as qualifying activities, various items that are made with the hope of getting to the bankable feasibility study stage, but without being there yet- such as 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, and bulk sampling (in reasonable sizes) for determining the effective grade (after dilution), and performing grinding tests and tests as to whether any separation process (e.g. flotation or solvent extraction) allows minimum quality specifications (provided it is not for determining the optimal processing method). ... Summaries of 9 February 2022 Internal T.I. 2020-0873931I7 under s. 66.1(6) – CEE- (f), s. 66.2(5) – CDE- (e) and s. 18(1)(b) – capital expenditure v. expense –current expense v. capital acquisition. ...

4 March 2018- 7:11pm CRA indicates that the purchase price of a subsurface mineral exploration right was CDE Email this Content The definition of “Canadian oil and gas property expense” includes the cost of a right to explore for Canadian hydrocarbons, but the definition of “Canadian development expense” does not explicitly include the cost of a right to explore for Canadian mineral resources. ... CRA also appeared to indicate that on the s. 85(1) transfer of a Canadian resource property with a nil balance in the relevant resource pool, a “nil” elected amount can be designated. ... Summaries of 7 February 2018 External T.I. 2016-0637221E5 under s. 66.2(5) – Canadian development expense and s. 85(1)(a). ...

Draft s. 18.2(3) deems amounts of previously capitalized interest that are otherwise deductible as CCA or resource pool deductions, but are denied as a deduction under s. 18.2(2), to have been allowed as deemed UCC or resource pool deductions- so as to prevent the taxpayer from receiving the “double benefit” of having a higher UCC or resource pool (potentially deductible in a future year) while at the same time having a restricted interest expense carryforward for future deduction. ... Summaries of PwC, “Tax Insights: Excessive interest and financing expenses limitation (EIFEL) regime,” Issue 2022-06, 15 February 2022 under s. 18.2(1) – adjusted taxable income – A, excluded entity, excluded interest, interest and financing expenses – A – para. (d), s. 18.2(2), s. 18.2(3), s. 18.2(4)(c), s. 18.21(1) – acceptable accounting standards and s. 18.21(2). ...

In addition to the most obvious items, CEE includes: environmental studies and community consultation sampling- generally only up to decision to bring the mine into production, but also where done to expand the mineral resource (but not where done for technical feasibility purposes) bulk sampling (in reasonable sizes) mineralogical analysis and laboratory testing of drilling cores resource estimation and deposit delineation deposit modelling and determination of cut-off grade testing of host rock stability, and testing of ore dilution and breakability metallurgical testing if for determining whether separation of pay metals is feasible (but not for determining the optimal method of separation) Rio Tinto found that expenditures incurred determining whether to proceed with an acquisition on capital account are currently deductible. ... Summary of 21 February 2019 Internal T.I. 2019-0796791I7 under s. 66.1(6) – CEE – para. ...

Furthermore, the charity must ensure it retains authority on the use of its resources. Those Guidelines also discussed related amendments that permit a registered charity to make a “qualifying disbursement,” by way of a gift or otherwise making resources available, to a “grantee organization” (i.e., a non-charitable organization or entity) provided that the disbursement is in furtherance of a charitable purpose of the charity and the charity ensures that the disbursement was exclusively used to advance charitable activities in furtherance of a charitable purpose of the charity. ... Summary of 29 November 2022 CTF Roundtable, Q.14 under s. 168(1)(f) and summaries of CG-032, Registered charities making grants to non-qualified donees (draft), 30 November 2022 under s. 168(1)(f), s. 149.1(1) – qualifying disbursement and charitable organization – (a). ...

It proposed to engage in scout and expansion drilling at surface, and in expansion and infill drilling underground, including related work such as the construction of underground infrastructure, in order to expand the resource. ... (e) of that definition – with the Company distributing its sales proceeds as a PUC distribution to Company B. ... Summaries of 2023 Ruling 2023-0961681R3 under s. 66.1(6) – CEE – (f) and s. 66(12.71). ...

(f) of the definition of Canadian exploration expense refers to expenses incurred for the purpose of determining the extent or quality etc. of a Canadian mineral resource including “for environmental studies or community consultations.” ... Summary of 15 November 2018 External T.I. 2018-0762201E5 under s. 66.1(6) – Canadian exploration expense – para. ...

This interpretation does not appear to accord with the CEE definition which, in its relevant aspect, requires only that the expense have been incurred for the purpose of finding or assessing a mineral resource. ... Summaries of Emmanuel Sala, "Flow-Through Share Financing: Recent Developments, Traps and Tips," 2015 CTF Annual Conference draft paper under s. 66.1(6) – Canadian exploration expense – (f), s. 66(12.6)(a), s. 66(15) – flow-through share. ...

The two ruling letters, when read together, may imply that CRA accepted that work conducted between the first and second rulings, which consisted mostly of analyzing data from drill holes that were drilled by previous owners of the mine and from drill core assays left by them, in order to arrive at an inferred or indicated resource, qualified as CEE. ... Summary of 2016 Ruling 2016-0639671R3 under s. 66.1(6)- Canadian exploration expense – para. ...