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S3-F8-C1 - Principal-business Corporations in the Resource Industries -- summary under Principal-Business Corporation

S3-F8-C1- Principal-business Corporations in the Resource Industries-- summary under Principal-Business Corporation Summary Under Tax Topics- Income Tax Act- Section 66- Subsection 66(15)- Principal-Business Corporation Meaning of petroleum products in s. 66(15)(a) 1.4 …[P]etroleum products…in paragraph (a) of the PBC definition, includes all steps up to the production and sale of a petroleum product as a raw material…. ... Meaning of Fabrication of Metals (s. 66(15)(e)) 1.7 Paragraph (e) of the PBC definition includes operations such as the manufacture of alloys (for example, brass, solder, and stainless steel) and the intermediate or final stages of manufacturing metals such as stamping, forming, machining, welding, cutting, or casting. … Comparison of resource and non-resource activities 1.11 A…corporation will generally qualify as a PBC if the corporation's activities of the kind described in [s. 66(15)] represent a larger or more important business operation than all other activities of the corporation combined…. 1.12 The following are important criteria for making [this] determination…: the amount of income derived from each business operation; the amount of gross revenue attributable to each business operation; the operating costs and expenses of each business operation; the capital employed in each business operation; and the time and effort expended by the employees on each business operation. ... For example, a mining corporation which has qualified as a PBC for many years might suffer a temporary decline in its mining activity in a particular year due to various problems, such as adverse economic conditions, labour problems, or other short-term difficulties. … [I]n determining whether a corporation qualifies as a PBC for a particular year, regard may be had to a future plan of the corporation to the extent that it is implemented in the year. ...

Brilliant Resources -- summary under Ss. 84(4.1)(a) and (b) distributions of proceeds

Brilliant Resources-- summary under Ss. 84(4.1)(a) and (b) distributions of proceeds Summary Under Tax Topics- Public Transactions- Spin-Offs & Distributions- Ss. 84(4.1)(a) and (b) distributions of proceeds Stated capital distribution by Brilliant Resources of cash expropriation proceeds in reliance on s. 84(4.1) Return of Capital The stated capital account maintained by the Corporation in respect of its Common Shares will be reduced by an amount equal to $0.145 multiplied by the number of Common Shares issued and outstanding as at the Return of Capital Record Date. ... The Subsidiary Ivory Resources Inc., a Caymans company which formerly engaged in exploration in Equatorial Guinea. ...

Marret Resource -- summary under Liquidity Program

Marret Resource-- summary under Liquidity Program Summary Under Tax Topics- Public Transactions- Other- Liquidity Program Marret Resource Corp. addition of annual redemption feature to its common shares Overview The Corporation's articles will be amended to provide for the creation of unlisted Class A Shares and for an annual liquidity right (ALR), i.e., an annual offer to redeem at a discount to NAV, in respect of both the Common Shares and Class A Shares (collectively, "Shares"). ... Its business is to lend to companies in the resource sector. Its reported issued share capital appears to be higher than its market cap. ... No more than 25% of the outstanding Shares of each class may be redeemed by March 31, 2015 – and thereafter, no more than 10% annually. ...

7 January 2013 External T.I. 2012-0460791E5 - Qualified Farm Property & Oil Reserves -- summary under Canadian Resource Property

7 January 2013 External T.I. 2012-0460791E5- Qualified Farm Property & Oil Reserves-- summary under Canadian Resource Property Summary Under Tax Topics- Income Tax Act- Section 66- Subsection 66(15)- Canadian Resource Property In response to a question "as to whether a taxpayer whose farm property meets the definition as a "qualified farm property"... within the meaning of subsection 110.6(1)...will be eligible to claim the capital gains deduction under subsection 110.6(2) on a subsequent disposition of the farm property in circumstances where petroleum or natural gas reserves are discovered on the property," CRA responded: any real property the principal value of which depends on its petroleum, natural gas or related hydrocarbon content will constitute a "Canadian resource property"....For these purposes "principal" means more than 50%. Where the taxpayer owns one right that includes both the surface right and the subsurface right, and more than 50% of the value of the real property depends on the petroleum or natural gas reserves, the right would constitute a Canadian resource property and the disposition of the right would result in the tax consequences described in the previous paragraph [i.e., income inclusion under ss. 66.2(1) and 59(3.2)(c), if a negative CCDE balance arises]. ...

Imperial Oil Resources Limited v. Canada (Attorney General), 2008 DTC 6657, 2008 FC 1037 -- summary under Payment & Receipt

Imperial Oil Resources Limited v. Canada (Attorney General), 2008 DTC 6657, 2008 FC 1037-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt embedded royalty reduction was not an amount received The Alberta government granted a reduction in the royalties the taxpayer otherwise would have been required to pay to Alberta on condition that the taxpayer invest in an expansion of the Syncrude project. ...

St. Ives Resources Ltd. v. MNR, 90 DTC 1375, [1990] 1 CTC 2539 (TCC), aff'd 92 DTC 6223 (FCTD), briefly aff'd in turn at 94 DTC 6261 (FCA) -- summary under Rectification & Rescission

Ives Resources Ltd. v. MNR, 90 DTC 1375, [1990] 1 CTC 2539 (TCC), aff'd 92 DTC 6223 (FCTD), briefly aff'd in turn at 94 DTC 6261 (FCA)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission must give effect to agreement In refusing to recognize a price rectification agreement, Sarchuk, J. stated (p. 1378): "Rectification is an 'equitable remedy' whereby one party to a contract seeks the court's intervention to rectify a written instrument which does not accurately reflect the terms agreed to orally by the parties prior to putting their agreement down in writing... the remedy of rectification is not available to correct a mistaken assumption of fact. ...

Commissioner of Taxation v Resource Capital Fund IV LP Commissioner of Taxation v Resource Capital Fund IV LP, [2019] FCAFC 51 -- summary under Paragraph (d)

Commissioner of Taxation v Resource Capital Fund IV LP Commissioner of Taxation v Resource Capital Fund IV LP, [2019] FCAFC 51-- summary under Paragraph (d) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Taxable Canadian Property- Paragraph (d) mine assets included processing operations Two Caymans investment LPs (“RCF IV” and RCF V”) whose limited partners were mostly U.S. residents, realized gains from the disposal of shares of significant shareholdings in a TSX-listed Australian corporation (Talison Lithium) which, through a grandchild corporation, held leases in Australia and carried out an operation there of mining lithium ores and processing them. ... This integration can be seen in the way in which Talison Lithium itself described the Greenbushes operations in its “Annual Information Form” …. the foregoing passage [in the AIF] draws no distinction between the activities of extraction, said to be mining by the respondents, and the activities of processing. … … The term “mine”, as a verb, is defined by s 8 of the Mining Act to mean any manner or method of “mining operations” and that term refers to a number of different means of refining a mineral. ...

Commissioner of Taxation v Resource Capital Fund IV LP Commissioner of Taxation v Resource Capital Fund IV LP, [2019] FCAFC 51 -- summary under Subparagraph 115(1)(a)(ii)

Commissioner of Taxation v Resource Capital Fund IV LP Commissioner of Taxation v Resource Capital Fund IV LP, [2019] FCAFC 51-- summary under Subparagraph 115(1)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 115- Subsection 115(1)- Paragraph 115(1)(a)- Subparagraph 115(1)(a)(ii) source of gain was in Australia because the sale occurred pursuant to an Australian Scheme of Arrangement Two Caymans investment LPs, whose limited partners were mostly U.S. residents, realized income-account gains from the disposal, pursuant to an Australian Scheme of Arrangement, of shares of significant shareholdings in a TSX-listed Australian corporation (Talison Lithium) which, through a grandchild corporation, held mining leases in Australia and carried out an operation there of mining lithium ores and processing them. ... In affirming this finding, the Full Court stated (at paras. 64-65): What bound the respondents to dispose of their shares and interests in Talison Lithium was not the entry into a contract of sale overseas but the convening of the scheme meeting, the approval at that meeting of the scheme of arrangement, the approval of that scheme by the Court, and the lodging of the order of the Court with the Australian Securities and Investment Commission …. ... That arrangement took place in Australia, and accordingly, because the scheme was the “proximate” origin of the profits earned, and because of the other connections with Australia summarised by the primary judge … including the location of the mine in Western Australia, those profits had a source in Australia. ...

Notice 269 – Draft GST/HST Memorandum 3.7, "Natural Resources" 15 February 2012 -- summary under Subsection 162(2)

Notice 269 – Draft GST/HST Memorandum 3.7, "Natural Resources" 15 February 2012-- summary under Subsection 162(2) Summary Under Tax Topics- Excise Tax Act- Section 162- Subsection 162(2) Overview of section 162 1. ... The Act does not define "explore" or "exploit" with respect to natural resources. ... The interest usually takes one of two forms – a royalty interest or a working interest. ...

Randy S. Morphy, Kim Maguire, "An Update on the Taxation of Farm-outs", Resource Sector Taxation, Vol. IX, No. 3, 2013, p. 661. -- summary under Canadian Resource Property

Morphy, Kim Maguire, "An Update on the Taxation of Farm-outs", Resource Sector Taxation, Vol. ... Canadian Pipelines & Petroleum Limiter et al. [fn 11: (2959), 21 DLR (2d) 497 (S.C.C.) at 169-70, although we note that in the particular case, the Court found that the option was rendered void and of no effect because of a regulatory prohibition. ... If the resource property subject to the option qualifies as a Canadian resource property (and presumably it would), [fn 12: A mineral property would qualify under paragraph (b) (any right, licence or privilege to prospect, explore drill or mine for minerals) in the case of a working interest and under paragraph (g) (any real property the principal value of which depends on mineral resource content) in the case of a fee simple interest. ...

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