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23 March 2011 Internal T.I. 2010-0389081I7 F - Disposition of a resource property -- summary under Paragraph 12(1)(g)

23 March 2011 Internal T.I. 2010-0389081I7 F- Disposition of a resource property-- summary under Paragraph 12(1)(g) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(g) deferred share consideration potentially not recognized until issuance The Vendor sold a percentage interest in mineral claims for consideration including shares to be issued by the public-company purchaser, to be issued over a four-year period. The Directorate noted that the shares’ market price could “fluctuate greatly,” and indicated that the TSO accordingly might: conclude that such portion of the proceeds of disposition for the Mining Properties by the Vendor is not determinable prior to the date of issuance of the shares by the Purchaser and that such portion of the proceeds of disposition would be recognized for tax purposes at the times of their issuance …. ...

23 March 2011 Internal T.I. 2010-0389081I7 F - Disposition of a resource property -- summary under Paragraph (a)

23 March 2011 Internal T.I. 2010-0389081I7 F- Disposition of a resource property-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Act- Section 54- Proceeds of Disposition- Paragraph (a) proceeds included full (undiscounted) deferred cash proceeds, but might exclude share consideration (with volatile market price) until issued The Vendor sold a percentage interest in mineral claims (the “Mining Properties”) for consideration including deferred cash payments and shares to be issued by the public-company Purchaser, in each case, to be paid or issued over a four-year period. ... Turning to the deferred share issuance consideration, the Directorate noted that the shares’ market price could “fluctuate greatly,” and indicated that the TSO accordingly might: conclude that such portion of the proceeds of disposition for the Mining Properties by the Vendor is not determinable prior to the date of issuance of the shares by the Purchaser and that such portion of the proceeds of disposition would be recognized for tax purposes at the times of their issuance …. ...

22 November 2011 External T.I. 2011-0420451E5 F - Canadian resource property -- summary under Paragraph (e)

CRA indicated that it was not prepared to extend its policy on farm-in arrangements to this situation (given that “carrying out the work on the claims does not give a right in the claims but potentially only an option to acquire them”), stating: Consequently … the amounts paid to carry out the work on the claims of Corporation B would be added to the cash payments provided for in the agreement and would be considered part of the overall consideration given by Corporation A to acquire a property. ... Consequently, taking into account the acquisition of the resource property that occurred at the time of the outlays, Corporation A could continue to deduct the deductible portion of its cumulative Canadian development expense account if it does not exercise the option. On the other hand, taking into account the acquisition of the resource property that took place at the time of the outlays, the exercise of the option would not entail any additional tax consequences to Corporation A or Corporation B. ...

6 February 2014 External T.I. 2013-0512191E5 - Mining Activities and SR & ED -- summary under Scientific Research & Experimental Development

6 February 2014 External T.I. 2013-0512191E5- Mining Activities and SR & ED-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development CEE excluded even if renounced An expenditure incurred by a resource corporation which qualifies as Canadian exploration expense cannot be a qualified expenditure in respect of SR&ED by virtue of para. ...

Anderson/Freehold -- summary under Taxable spin-offs

Anderson will be deemed to have filed an election under ITA – s. 89(1) – (c) to not be a public corporation. ... "By virtue of New Anderson having acquired approximately 92% of Anderson's Canadian resource property…it is anticipated that the successor tax election will allow New Anderson to also acquire the undeducted resource tax pools of Anderson, on a ‘successored' basis…." Accordingly, it is anticipated that New Anderson will have Canadian tax pools which may be applied by it to shelter future income, including successor resource pools. ...

Chalice/Coventry -- summary under Ss. 84(4.1)(a) and (b) distributions of proceeds

Chalice/Coventry-- 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 Chalice Gold acquisition of Coventry Resources assets for shares, followed by share distribution Overview Under a BC Plan of Arrangement, Coventry is to transfer most of its subsidiaries (the "Targets") to Western Rift (a subsidiary of Chalice) in consideration for Chalice shares, which Coventry will then transfer to its shareholders as a stated capital distribution. ... See detailed summary under Cross-Border Acquisitions – Inbound – Asset sale/share distribution. ...

Aurora/ CanniMed -- summary under Unsolicited Bids (corporate)

CanniMed’s Newstrike Resources bid On November 14, Aurora issued a press release acknowledging that it had delivered a proposal to CanniMed for a business combination. On November 17, 2017, the date Aurora's proposal expired, CanniMed announced that it had entered into a definitive agreement to acquire Newstrike Resources Ltd. Aurora’s Offer is subject to the condition that the proposed acquisition of Newstrike Resources shall not have proceeded, and any acquisition agreement for such acquisition shall have been terminated. ...

BLP Group plc v Commissioners of Customs & Excise, [1995] EUECJ C-4/94 (ECJ (5th Chamber)) -- summary under Supply

BLP Group plc v Commissioners of Customs & Excise, [1995] EUECJ C-4/94 (ECJ (5th Chamber))-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply mere borrowing of money is not a supply BLP was a management holding company which provided services to a group of trading companies producing goods for use in the furniture and DIY industries. ... In finding that taking out a loan did not involve a VATable transaction by the borrower at all, even if it pays interest (it was the mere recipient of a service provided by the lender) the Court stated (at para. 47): The taking up of a loan and the selling of an interest in a company are not … operations of the same type for the purposes of the VAT system — nor are they, moreover, for an undertaking's operational purposes, since the income from the sale of shares is part of the undertaking's own resources, whereas the loan is part of its borrowed resources — because that system focuses on transactions and makes a clear distinction between taxable and exempt transactions. ...

ExxonMobil/InterOil -- summary under Canadian Buyco

ExxonMobil/InterOil-- summary under Canadian Buyco Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- Cross-Border Acquisitions- Inbound- Canadian Buyco Acquisition by ExxonMobil Canadian purchaser of InterOil for fixed-value ExxonMobil shares and escrowed cash payment subject to reduction based on subsequent resource estimate Overview It is proposed that a newly-incorporated B.C. subsidiary of ExxonMobil will acquire InterOil under a Yukon Plan of Arrangement. ... However the cash “contingent resource payment” (or “CRP”) of U.S.$26.87 per share, which will be held under an escrow arrangement, will have to be repaid in full to AcquisitionCo if an interim resource assessment of a PNG natural gas project of InterOil, which is expected to be completed in the 2nd quarter of 2017, shows a resource of less than 6.2 trillion cubic feet equivalent ("tcfe"), and with the CRP having to be so repaid on a pro rata basis if the interim assessment shows a resource of between 6.2 and 10 tcfe. ... It is expected that the Interim Resource Certification will be completed in the second quarter of 2017, and that the CRP Payouts will be made shortly thereafter. ...

Sarah S. Chiu, "Half-Year Rule and Amalgamations", Resource Sector Taxation, Volume IX, No. 2, 2013, p. 638 -- summary under Subsection 1100(2)

Chiu, "Half-Year Rule and Amalgamations", Resource Sector Taxation, Volume IX, No. 2, 2013, p. 638-- summary under Subsection 1100(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 1100- Subsection 1100(2) A textual and contextual interpretation of the half-year rule suggests that the rule may not apply to amalgamations. ... See, also, Black & Decker Manufacturing Co. v. R., [1975] 1. S.C.R. 411 (S.C.C.).] ...

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