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Barrick Gold Corporation v. The Queen, 2017 TCC 18 -- summary under Subparagraph 1204(1)(b)(ii)

The Minister disallowed the inclusion of the profit from closing out the Forward Contracts in the taxpayer’s gross resource profits within the meaning of Reg. 1204(1)(b) (thereby reducing its resource allowance). ... In allowing the taxpayer’s appeal, Paris J stated (at paras 33, 37 and 39): … [3850625] confirmed that the test for whether an item of income should be included in gross resource profits is “whether the [income in question is] sufficiently connected to the [taxpayer’s] production and processing activities to constitute income from that source”….. ... …[T]he Forward Contracts were entered into and closed out in the course of the Appellant’s business of production and processing from the Doyon Mine. … [T]he Appellant’s sole reason for entering into the Forward Contracts was to hedge the risk of price fluctuations in the price of gold that it expected to produce from the Doyon Mine. … ...

Canada (Attorney General) v 18335898 Alberta Ltd (Whitecap Energy Inc), 2023 ABKB 357 -- summary under Subsection 209(6)

The Attorney General sought to revive Whitecap Energy pursuant to s. 208 of the Business Corporations Act (Alberta) in order that it could be assessed by CRA which, in turn, would permit an assessment of Whitecap Resources under ITA s. 160. Principally at issue was whether the Attorney General had standing as an “interested party,” which was relevantly defined in ABCA s. 206.1 to “mean … (a) … a creditor of a dissolved corporation … or (d) a person designated as an interested person by an order of the Court.” ... The liability does not become a debt until the taxes are assessed and a Notice of Assessment is issued (sections 158, 227, and 248(2) …. and cf Brogan Family Trust …). ...

Wesdome Gold Mines Ltd. v. ARQ, 2016 QCCQ 1504 -- summary under Subparagraph (vi)

ARQ, 2016 QCCQ 1504-- summary under Subparagraph (vi) Summary Under Tax Topics- Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (f)- Subparagraph (vi) mine on care and maintenance was a closed mine for CEE purposes A mining company (“McWatters”) operated its Kiena gold mine, whose primary facilities were situated at Lac de Montigny near Val-d’Or, until October 2002, when it put the mine on care and maintenance (having exhausted the reserves, although there were still measured and indicated resources), and put it up for sale. ... ARQ assessed on the basis that Wesdome’s related expenditure did not qualify as Canadian exploration expense under s. 395(c) of the Taxation Act (essentially identical to ITA, s. 66.1(6) – Canadian exploration expense – (f)(vi)), as being “any expense that may reasonably be related to a mine in the mineral resource that has come into production in reasonable commercial quantities or to an actual or potential extension of such a mine.” ... And at paras. 82-86: The uncontradicted evidence demonstrates that in October 2002, when McWatters ceased operations at the Kiena mine, the identified extractable resources were not of a sufficient quantity and quality to economically justify maintaining operations. ...

DEML Investments Limited v. The King, 2024 TCC 27 -- summary under Subsection 245(4)

DERP2 then distributed its resource properties to DEML as a return of capital, thereby increasing the COGPE balance of DEML and reducing the ACB of DEML’s partnership interest by the FMV of the rights (higher than the value a year earlier) – but with these items effectively being approximately reversed at the partnership year end as a result of DERP2’s proceeds of the distribution of the PNG rights being allocated to its partners. After then seeding DERP2 with a small resource property that was of interest to a third-party purchaser, DEML sold its partnership interest to that purchaser, thereby realizing a capital loss, which it then carried back to offset a capital gain it had previously realized. ... That is even more so when those losses are based on non-capital CRP [Canadian resource property], that will also be deducted through CCOGPE pools at a 100% inclusion rate thus creating a double deduction. ...

Larkin v. The Queen, 2020 TCC 98 (Informal Procedure) -- summary under Business Source/Reasonable Expectation of Profit

During 201 and for some time before and after 2011, he worked on a variety of resource projects (described as “high risk and high speculation”) (para. 13), for example, seeking to exploit a novel graphene production process, unsuccessfully bidding on an oil sands property and then a kerogen property, developing a new technique to liberate nickel from ore, and a down hole water separation project. ... In finding that the taxpayer had a business, Masse DJ stated (at paras 34, 35, 40): [I]t is not uncommon for high risk and speculative ventures such as prospecting, mining, resource extraction and indeed many other entrepreneurial activities, not to show any profit for many years. … Stewart confirms … that the non-existence of income is not determinative of whether a taxpayer’s activities constitute a source of income. … He certainly could demonstrate better business practices and I note that his record keeping leaves much to be desired but I still conclude that he conducted his activities with a level of commerciality sufficient to constitute a business. ...

7 June 2017 CPTS Roundtable, 2017-0695131C6 -- summary under Paragraph (d)

7 June 2017 CPTS Roundtable, 2017-0695131C6-- summary under Paragraph (d) Summary Under Tax Topics- Income Tax Act- Section 66- Subsection 66(15)- Canadian Resource Property- Paragraph (d) Q.2- a Canadian resource royalty interest requires a right to “take production” Does the reference in para. ... CRA responded: An “interest” in the well or accumulation … requires that the payer must have a right to take production from the well or accumulation. ... Of course, the conditions in paragraph (d) of the [CRP] definition … must be met …. ...

InterOil Corp. v. Mulacek, 2016 YKCA 14 -- summary under Clause 182(5)(f)

Booth of Paradigm Capital, an expert in the valuation of reserves and resource estimates for the oil and gas industry, who concluded that the consideration contemplated by the arrangement was inadequate. ... In reversing the chambers judge and dismissing the application under s. 195, Newbury JA stated (at para 40): … Instead of ‘delving into’ the question of value (see [BCE Inc. v. 1976 Debentureholders, 2008 SCC 69] at para. 141), [the chambers judge] relied on the truism that the shareholders were “entitled to make the decision”. ... Given the ‘red flags’ in this case – the absence of a fairness opinion from an independent expert, the failure of Morgan Stanley to assess the value of the CRP as compared with the value of the PRL prospects (again, the company’s primary asset); the deficiencies pointed out by Mr. ...

9 February 2022 Internal T.I. 2020-0873931I7 - Cover Letter - Mining Expenditure Review Table -- summary under Paragraph (f)

., to expose steeply-dipping mineralization) and digging test pits (for shallow mineralization) Definition or infill drilling, 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 Bulk sampling (in reasonable sizes) for determining the effective grade (after dilution), performing grinding tests and whether any separation process (e.g. flotation or solvent extraction) allows minimum quality specifications- provided it is not for determining the optimal processing method Note: various of the above items do not qualify as CEE if they are performed for camp, infrastructure or mine design purposes. ... (f) potentially may include activities engaged in after the feasibility study preparation “to increase the level of geological knowledge and confidence in the mineral resource.” ... The following are deductible under s. 9 if incurred before making a decision to bring the mine into production (otherwise generally Class 41 or 41.2 assets or other depreciable property, or Class 14.1 if the property is not acquired – or CDE under para. ...

ARQ v. Wesdome Gold Mines Ltd., 2018 QCCA 518 (Queb. C.A.) -- summary under Subparagraph (vi)

ARQ assessed on the basis that Wesdome’s related expenditure did not qualify as Canadian exploration expense under s. 395(c) of the Taxation Act (essentially identical to ITA, s. 66.1(6) – Canadian exploration expense – (f)(vi)), as being “any expense that may reasonably be related to a mine in the mineral resource that has come into production in reasonable commercial quantities or to an actual or potential extension of such a mine.” In confirming the finding of Godbout J below that Wesdome’s expenditures qualified as CEE, Levesque JCA first stated (at paras. 80-81, TaxInterpretations translation): [T]he judge … correctly concluded that the provisions of section T.A. paragraph 395(c) did not require that the exploration expenses were to be incurred respecting a “new mine” to be eligible for tax credits. … [I]f the legislator had wished the contrary, this could have been expressly provided in the provision. ... It is true that the judge assimilated this concept to the fact that the Kiena mine was “in practice … considered as closed.” ...

10 October 2006 Internal T.I. 2006-0169051I7 - Successor Pool Issues -- summary under Subsection 66.7(5)

10 October 2006 Internal T.I. 2006-0169051I7- Successor Pool Issues-- summary under Subsection 66.7(5) Summary Under Tax Topics- Income Tax Act- Section 66.7- Subsection 66.7(5) Given that the successor provisions concern income attributable to " production from the particular property", rather than income attributable to the "particular property", a taxpayer may deduct its successored resource pools against income from a particular successor property (e.g., a lease) that has only arisen as a result of development of the property after the successoring of the resource pools, even though the further development could itself be regarded as giving rise to a new form of Canadian resource property (the oil or gas well). ...

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