Search - ”资源化利用" resource

12 June 1992 Roundtable, 9216600 F- Resource Industry Farmout Transactions Unedited CRA Tags 66.1(6)(a), 66.2(5)(b), 66(12.1)   5-921660   John Chan   957-8975 1992 CPTS ROUNDTABLE QUESTION In February, 1991 Revenue Canada announced to the Canadian Petroleum Tax Society that it was reviewing the income tax treatment of farmouts.  ... In summary, the favourable tax treatment would be extended in the following situations: (a)      where the farmee explores and develops an unproven resource property of the farmor and the farmee receives an interest in that unproven resource property; (b)      where the farmee explores and develops an unproven resource property of the farmor and the farmee receives an interest in another unproven resource property of the farmor. ... The question and answer was reviewed by John Kurrant, Oil & Gas Specialist on June 12 and he said that he does not have any concerns. ...

March 30, 1995 Audit Technical Support Division Resource Industries Industry Specialist Services Section B. ... Cloutier 7-950601 XXXXXXXXXX Revised Resource Allowance in nil years We are writing in response to your March 2, 1995 request for our opinion on whether producers in the Oil & Gas and Mining Industries may increase resource allowance claims in taxation years with nil taxable income. ... The notion of reflecting amended resource allowance deductions for previous years in unclaimed resource pool and/or UCC balances and non-capital loss carried forward is premised on there being a change to the resource allowance claimed. ...

Resource Taxation- Crown Lease Rentals/ 24. Principal Business Corporation Renunciations/ 25. ... The grossed-up total of withholding tax is calculated by applying the following formula: Required payment = tax rate X interest payment 100 minus tax rate For example, the required payment of withholding tax on an interest payment of $1,000, assuming a withholding rate of 15%, would be calculated as follows: 15 X $1,000 = $176.47 (100- 15) Canada-U.S. ... Department's Position The Department is presently studying the impact of the decisions in Hickman Motors and Mark Resources. ...

18 June 2015 STEP Roundtable Q. 10, 2015-0578541C6- 2015 STEP – Q10- Interest in a Trust as TCP CRA Tags 116(5.01) 116(6.1) 116(5.02) 116(6) 116(5) 248(1) Principal Issues: A testator leaves an estate, more than 50% of which is comprised of real property situated in Canada, (the testator's principal residence). ... Interest in a Trust as Taxable Canadian Property The definition of "taxable Canadian property" (TCP) in subsection 248(1) provides that an interest in a trust (other than a unit of a mutual fund trust or an income interest in a trust resident in Canada) will be TCP if, at any particular time during the 60 month period that ends at that time, more than 50% of the fair market value (FMV) of the interest was derived directly or indirectly from one or any combination of real or immovable property situated in Canada, Canadian resource properties, timber resource properties, and options or interests in such properties. ...

13 February 2017 Roundtable, 2017-0684491C6- CPA-BC & CRA Roundtable 2017 Principal Issues: Whether the CRA will re-introduce a dedicated phone line for tax professionals. ... CPA-BC & CRA Roundtable 2017 Question 16: We were very excited about the introduction of the CRA’s “professional designated phone line”, only to find out that this was meant for small practitioners who have no tax advisers. ... The DTS is intended to be a technical resource for service providers rather than a problem resolution line. ...

3 May 1994 Roundtable Q. 1, 9411620- SAFE INCOME & ALBERTA ROYALTY TAX CREDITS Unedited CRA Tags 55(2) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Principal Issues:- Alberta Royalty Tax Credits & Safe Income Position TAKEN:- treated like government assistence for purposes of safe income Reasons FOR POSITION TAKEN:- Consistent with position taken in 91 paper presented by M. ... It is the Department's current position that an Alberta Royalty Tax Credit is not included in a taxpayer's income under paragraph 12(1)(x) of the Act and it does not reduce any of the taxpayer's resource pools. ...

11 September 2006 Roundtable, 2006-0185642C6- 2006 STEP Questions 7,8,10,11, & 12 Unedited CRA Tags 116 162(7) 233.1 Principal Issues: 7-8: Administrative issues relating to the delays in obtaining a 116 certificate of compliance. 10-12: Administrative issues relating to foreign reporting requirements 2006 STEP Round Table Q7. ... Response Our International Tax Directorate has been working with CRA staff in the tax services offices and the Regional offices to develop a risk-based audit strategy in order to make better use of our resources which should reduce the delays for most requests. ... Because audit resources are allocated to issues with the greatest risk of non-compliance, the foreign reporting information has resulted in improved file selection. ...

13 February 1997 CTF Roundtable Q. 1, 9621950- 1996 ONTARIO TAX CONFERENCE- QS & AS Unedited CRA Tags 212(1)(d) 55(2) 55(3) 112(3.2) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... First Scenario Purchase of First 50 Shares- capital dividend capital loss500,000 s. 112(3.2) reduction*(375,000) reduced loss125,000 * The subsection 112(3.2) reduction is: 500,000- capital dividend (125,000)- 25% of capital gain on death on 50 Class A shares 375,000 Purchase of Second 50 Shares- taxable dividend capital loss500,000 s. 112(3.2) reduction nil loss500,000 Total Loss First 50 shares 125,000 Second 50 shares 500,000 Total 625,000 Second Scenario capital loss1,000,000 s. 112(3.2) reduction* (250,000) reduced loss750,000 *The subsection 112(3.2) reduction is: the lesser of $500,000 (the capital dividend) and $1,000,000 (the loss otherwise determined) minus $250,000 (25% of the capital gain on death on 100 Class A shares) Response Yes. ... Question #2 If a taxpayer develops computer software for use in the taxpayer's business (not for resale), using internal resources, and the expenditures do not qualify as Scientific Research & Development Expenditures ("SR&ED"), does the taxpayer have to capitalize these costs or can these costs be deducted on a current basis? ...

Aux fins du paragraphe 55(2) de la Loi, le montant que la corporation ajoute au «revenu sauf» pour l'année en cours est-il de 600 $ ou de 700 $? ... Le total majoré des retenues à la source est calculé au moyen de la formule suivante: Paiement requis = taux d'impôt X paiement de l'intérêt 100 moins le taux d'impôt Par exemple, les retenues à la source qu'il faut verser sur un paiement d'intérêt de 1 000 $, en supposant un taux de retenues à la source de 15 %, se calculent comme suit: 15 X 1 000 $ = 176,47 (100- 15) Convention fiscale entre le Canada et les É. ... Position du Ministère Le Ministère étudie actuellement les répercussions des décisions dans les affaires Hickman Motors et Mark Resources. ...

Cross-functional working groups have been initiated by the project team to determine the impact of IFRS on GST/HST and taxable income: ==> T2 Corporation Return and General Index of Financial Information (GIFI); ==> Instalment Payments; ==> Business Combinations; ==> International Transactions; ==> Domestic Issues; ==> Specialized Industries including Resource, Banking and Insurance. ...