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28 November 2010 CTF Annual Roundtable, 2010-0384341C6- Flow-through Shares-- summary under Flow-Through Share Summary Under Tax Topics- Income Tax Act- Section 66- Subsection 66(15)- Flow-Through Share flow-through unit Respecting whether CEE can be renounced under a unit flow-through share agreement in respect of the portion of the subscription price allocated to a warrant to acquire a share that is not a flow-through share, CRA stated: CEE can be renounced only in respect of the portion of the subscription price allocated to a warrant which represents a right to acquire a share that would be a flow-through share [as] pursuant to paragraph (b) of … "flow-through share," the amount of resource expenses that may be renounced under the agreement cannot exceed the amount of consideration received by the corporation for the flow-through share or the right to acquire the flow-through share…. ...

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 …. ...

7 June 2017 CPTS Roundtable, 2017-0695131C6-- summary under Proceeds of Disposition Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Proceeds of Disposition Q.1- Daishowa extends beyond reforestation and reclamation obligations only on a case-by-case basis The 2014 Alberta CPA Roundtable, Q,1 indicated that the Daishowa principle applied to the resource industry. ... The SCC also implied, in obiter dicta, that its decision could apply to reclamation obligations in the mining and oil and gas industries. … … It is CRA’s position that reforestation obligations in the forest industry and reclamation obligations in the mining and oil and gas industries are generally embedded in the related tenures or rights, as they cannot usually be severed and would therefore depress the value. Furthermore, the CRA’s position does not generally extend to sales transactions outside the resource industries but we are willing to consider fact situations on a case by case basis. ...

29 November 2022 CTF Roundtable Q. 2, 2022-0950501C6- Section 116 and Taxable Canadian Property-- summary under Subsection 116(5) Summary Under Tax Topics- Income Tax Act- Section 116- Subsection 116(5) CRA generally will not provide advance guidance on TCP status The determination of whether for shares of a private corporation, interests in a partnership or interests in a trust are TCP can be complicated because it must be determined if at any time in the previous 60-month period more than 50% of the fair market value of the share or interest was derived directly or indirectly from real or immovable property, Canadian resource properties, timber resource properties and options or interests in these properties. ... Although the Income Tax Rulings program is there to provide advance comfort on the tax consequences of a transaction, as noted in IC70-6R12, CRA will not confirm the fair market value of a property, and the Rulings program is not in a position to verify the facts provided – and there are also timing considerations. ...

CRA responded: FID is dependent on many things including a particular taxpayer’s circumstances, critical time path, availability of equipment, and resources. ... Consequently, the CRA does not accept that there is bright line test, such as FID, to determine the characterization of expenses for income tax purposes. … [E]xpenditures in respect of research in determining economic viability may be considered to be on income account.... ... If so, it is denied current deduction …. … The postponement or cancellation of a project does not alter the nature of an expense incurred in connection with such project. ...

Regarding Girard, CRA stated: The CRA does not consider that it must apply to the court in all cases where it issues a notice of assessment following a bankruptcy or the filing of a proposal for a tax debt relating to a taxation year ending on a day preceding the date of the bankruptcy or proposal, in order to ensure sound administration and reasonable use of judicial resources. ... Where the particular context of a case so requires, in applying Girard, the CRA will seek leave of the court under section 69.4 B.I.A. to lift the stay of proceedings. … In Girard, the presumption of validity of notices of assessment under subsection 152(8) I.T.A. was not at issue. … In the event that a trustee contests the CRA's proof of claim, the legal effects of the notice of assessment, including the procedure for contesting the assessment and the time limits associated with it, are suspended until the CRA obtains the lifting of the suspension of proceedings under section 69.4 B.I.A., pursuant to the Girard decision. ...

. … The onus is on the taxpayer to provide support for the calculation of safe income that can reasonably be viewed as contributing to the capital gain on a share. The CRA expects the supporting documentation to be organized as an accumulation of year-by-year computations. … …[W]here…the taxpayer offers an alternative proxy such as the accounting retained earnings or adjusted retained earnings balance…the CRA auditor might conclude that retained earnings is a fair proxy for safe income on hand but only after a very stringent validation process. ... …[W]hen a taxpayer makes a request to the CRA to obtain a copy of income tax returns and/or notices of assessment, the CRA will attempt, in regards to available resources, to provide the requested documentation. ...