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11 July 2002 External T.I. 2002-0126795 F- RESSOURCES INTERMEDIAIRES REVENU EX-- summary under Paragraph 81(1)(h) Summary Under Tax Topics- Income Tax Act- Section 81- Subsection 81(1)- Paragraph 81(1)(h) contributions paid to a Quebec intermediate resource have been treated as means-based assistance CCRA noted: [W]e have determined in the past that a contribution paid by an institution to a family-type resource or an intermediate resource under the A ct respecting health services and social services was usually a social assistance benefit paid to an individual under a provincially legislated program, on the basis of a means, needs and income test. In addition, where a user has been referred to a family-type resource or an intermediate resource by a "public institution" under [such] Act … part of the user’s contribution may also constitute such a benefit. This would be the case, for example, for any portion of a user's contribution that comes from the guaranteed income supplement or spouse's allowance paid in accordance with the Old Age Security Act or that comes from amounts of last-resort financial assistance paid under the [Quebec] Employment Assistance Program …. ...

., physical, chemical or mechanical) characteristics of the mineral resource Regarding whether the test of incurring an expense “for the purpose of determining the existence, location, extent, or quality of a mineral resource” (the “CEE Purpose Test”) would generally include expenses for determining the economic feasibility of a deposit, such as expenses for preparing pre-feasibility or feasibility studies (including expenses for determining the cut-off grade of the deposit), market studies or studies for determining the anticipated long-term price of a mineral, based on an expansive interpretation of the word “quality,” CRA noted: “the word ‘quality’ could be capable of an interpretation that either includes the concept of commercial value or that instead focuses more narrowly on the physical or inherent aspects of a particular item having regard to the ejusdem generis rule, it was to be noted that “the first three words in the list in the CEE Purpose Test” referred to “the inherent physical characteristics of the mineral resource,” which suggested that the word the word “quality” should be similarly “limited to inherent characteristics of the mineral resource,” so that it “could encompass other inherent characteristics of the mineral resource such as its chemical composition or mechanical properties (e.g., strength or porosity).” various materials suggested that the purpose to the provision was “the search for, or discovery of, the minerals in the ground,” and that expenses related to “external factors, for example the cost of bringing a product to purchasers, including marketing and distribution costs … or to the overall assessment of economic viability through a pre-feasibility study or feasibility study, extend well beyond the focused nature of an incentive targeted at the activity of mineral exploration.” CRA concluded: [E]xpenses that qualify for CEE do not … include expenses for determining the economic viability of a mineral resource if those expenses do not relate to a determination of the natural (e.g., physical, chemical or mechanical) characteristics of the mineral resource. Such expenses are too remote to be described as expenses incurred for the purpose of determining the “quality” of a resource. ...

24 May 2005 External T.I. 2005-0121291E5 F- Processing in Canada of ore-- summary under Clause Subparagraph 1204(1)(b)(iii)(A) Summary Under Tax Topics- Income Tax Regulations- Regulation 1204- Subsection 1204(1)- Paragraph 1204(1)(b)- Subparagraph 1204(1)(b)(iii)- Clause Subparagraph 1204(1)(b)(iii)(A) second crushing of nickel ore at the surface generated gross resource profits Mineco crushes nickel ore underground in its mine. ... CRA stated: [T]he revenues that Opco would earn in a particular year from the Second Crushing activity could be included in computing its GRP for that year under clause 1204(1)(b)(iii)(A) … since they could constitute revenues for the year from the processing in Canada of ore derived from mineral resources in Canada that would not be mined by Opco to any stage that is not beyond the prime metal stage or its equivalent. ...

21 May 2014 External T.I. 2014-0528021E5- Classification of Timber Limits-- summary under Schedule VI Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule VI timber limit v. timber resource property Standing timber is harvested and the land is subsequently disposed of at a gain. CRA stated: Generally a right not categorized as a "timber resource property" will be a timber limit. ... Timber limits usually include, among others, the right to cut which arises from the ownership of private land with timber. … [T]he cost of land with standing timber characterized as a timber limit would be more appropriately included in Schedule VI rather than under Class 15 of Schedule IV…. ...

Carried on"): Respecting the exclusion in Article XIII, paragraph 4 of the Canada-Netherlands Convention for property (other than rental property) in which the business of the company is carried on, RC stated that in its view "Oil & Gas reserves and royalty interests will be excluded from the definition of immovable property... if the owner is actively engaged in the exploitation of natural resources and if such assets are actively exploited or kept for future exploitation by such owner.... [A]s a general rule, in order for a company to be 'actively engaged' in the exploitation of natural resources, the company must be directly involved in the management and daily activities of the exploitation process on a regular, continuous and substantial basis, and the company's employees must devote time, work and energy to the exploitation. ...

16 June 2017 External T.I. 2016-0674541E5- Mineral Certification-- summary under Paragraph (f) Summary Under Tax Topics- Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (f) exploring a placer jade deposit did not qualify as CEE The Minister of Natural Resources advised CRA that nephrite (a type of jade) to be extracted from the in-situ deposits on the subject property was an industrial mineral contained in non-bedded deposits – but excluding placer nephrite deposits, which were considered to not qualify as “a mineral deposit in respect of which...the principal mineral extracted is an industrial mineral contained in a non-bedded deposit.” ...

19 January 2018 External T.I. 2017-0683501E5- Flow-Through Shares-- summary under Subsection 40(12) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(12) non-flow through shares can be part of a flow-through share class A taxpayer subscribes cash for a publicly listed common share (the “Share”) of a resource company, and donates it to a qualified donee. ... However, it is necessary for the taxpayer to have acquired a flow-through share (or certain partnership interests …) in order for a taxpayer to have an exemption threshold in respect of a flow-through share class of property to which subsection 40(12) of the Act would apply. Accordingly, where a taxpayer has no exemption threshold … with respect to a flow-through share class of property, the deemed capital gain from a disposition of a capital property included in that flow-through share class of property referred to in subsection 40(12) would likely be zero …. ...

9 December 2020 External T.I. 2020-0852321E5- Flow Through Shares- Fees Paid to Promoter-- summary under Paragraph 6202.1(1)(b) Summary Under Tax Topics- Income Tax Regulations- Regulation 6202.1- Subsection 6202.1(1)- Paragraph 6202.1(1)(b) payment by a flow-through share issuer of fees for investor procurement services of an arm’s length promoter would not taint the shares as prescribed shares A principal-business corporation (the “Issuer”) issues publicly-listed shares pursuant to flow-through share agreements to individual investors (the “Investors”), who sell their shares to an end-purchaser (the “Liquidity Provider”) after the renunciation of eligible resource expenditures. ... Generally, we would not expect that the payment of an Offering Assistance Fee by the Issuer to the Promotor of a FTS offering would, in and by itself, cause shares issued under the FTS offering … [under] section 6202.1 … if the Offering Assistance Fee is paid in circumstances where all the parties involved in the FTS offering, namely the Issuer, the Investor, the Promotor and the Liquidity Provider, deal with one another at arm’s length and the amount of the Offering Assistance Fee is equal to the fair market value of the services for which it is paid. … [A]ll of the facts and circumstances surrounding a FTS offering would need to be considered in detail before concluding whether a particular share issued under that FTS offering is a prescribed share …. ...

CRA stated: If the main focus of a business conducted with a reasonable expectation of profit (a commercial woodlot) is not lumbering or logging, but is planting, nurturing and harvesting trees pursuant to a forestry management or other similar resource plan and significant attention is paid to manage the growth, health, quality and composition of the stands, it is generally considered a farming business (a commercial farm woodlot). If the main focus of a business is logging (a commercial non-farm woodlot), and is not growing, nurturing and harvesting trees, the fact that reforestation activities are carried out would not transform that business into a farming operation. … [T]he forestry activities that take place on your farmland are farming. ...

After indicating that the courses offered by your institution “would not be post-secondary level courses since they do not lead to university credits” so that they did not qualify under s. 118.5(1)(a)(i), CRA went on to discuss ss. 118.5(1)(a)(ii) and (ii.2)(B), and stated: In addition to being recognized by the Minister of Human Resources Development as a recognized educational institution, the conditions in subparagraph 118.5(1)(a)(ii.2) must be satisfied for continuing education courses you offer to individuals who are members of a professional order to be eligible for the tuition tax credit. ... Whether it is reasonable to consider that the reason for an individual's registration at an institution is to enable the individual to acquire or improve the skill necessary to carry on an occupation is a question of fact …. ...