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7 June 1990 Ministerial Correspondence 5900454 F- Diamond Deposits- Mineral Resource Unedited CRA Tags 248(1) mineral resource 24(1) File No. 5-900454   G.R. White   (613) 957-8585 Attention:   19(1) June 7, 1990 Dear Sirs: Re:  Diamond Deposits- Mineral Resource We are writing in reply to your letter dated April 12, 1990 in which you requested certification that a diamond deposit discovered 24(1) would qualify as a mineral resource as that term is defined in subsection 248(1) of the Income Tax Act (the "Act"). ... Yours truly, Section ChiefResource Industries SectionBilingual Services and Resource Industrial DivisionRulings Directorate ...

20 September 1989 Ministerial Correspondence 32244 F- Existence of a Joint Venture or Partnership Unedited CRA Tags n/a   September 20, 1989 LEGAL SERVICES- TAXATION RULINGS DIRECTORATE   Resource Industries Attn:  C.T.A. MacNab Section General Counsel John Shaw   957-8968   File No. 3-2244 Subject: 24(1) We enclose a copy an adverse decision- D & B Oilfield Contracting Ltd. v. ...

16 May 1990 Ministerial Correspondence 57904 F- CCA Class 28- Major Expansion Unedited CRA Tags n/a 24(1) File No. 5-7904   A. Nelson   (613) 957-8984 19(1) May 16, 1990 Re:  24(1) Opinion Request We are writing in reply to your letter of April 14, 1989, wherein you request our opinion concerning whether  24(1) will have a major expansion for the purposes of subparagraph (a)(ii) of Class 28, Schedule II of the Regulations to the Income Tax Act ("Class 28"). ... Position 24(1) Yours truly, Section ChiefResource Industries SectionBilingual Services and ResourceIndustries DivisionRulings Directorate Principal Issue Sheet 24(1) Allan Nelson   Resource Industries Issue 24(1) 23 21(1)(b) We advised Current Amendments of the position that we were adopting, requesting them to inform Finance accordingly. ...

23 July 1990 Ministerial Correspondence 901034 F- Option to Acquire Shares Unedited CRA Tags 49(1)   901034                                           A. ... An individual who is a share holder of a private corporation grants an option to another person to acquire shares of the private corporation held by the individual. 2.        ... Yours truly,   for Acting Director Bilingual Services and Resource   Industries Division Rulings Directorate ...

18 June 1990 Ministerial Correspondence 900274 F- Definition of Family Farm Corporation Unedited CRA Tags n/a 24(1) File No. 900274   C.R. ... Some of the factors to consider are as follows:-     are the time, activities and resources devoted to processing minor compared to those devoted to raising ducks and geese,-     is the total operation accounted for a farming and is it in fact difficult to separate the processing records from the other operations, and-     are the customers of both operations the same? ... IT-145R (see paragraph 9) IT-206   IT-433 (see paragraph 6) We trust these comments will be helpful. ...

The Department of Natural Resources Canada administers the ecoENERGY Retrofit – Homes program. I am therefore forwarding a copy of our correspondence to the Honourable Joe Oliver‚ Minister of Natural Resources, for his consideration. You can get more information on the ecoENERGY Retrofit – Homes program on the Natural Resources Canada Web site at www.oee.nrcan.gc.ca/residential/6551 or by calling Service Canada at 1-800-622-6232. ...

Assume the same facts in 1. above except that B will incur $300 of CEE and $500 of CDE while taxpayer A will incur $200 on Class 41 assets.       ... B.     It is the Department's position, as outlined in paragraph 11 of Interpretation Bulletin 125R3, that to the extent that an owner of a resource property (the "farmor") transfers a part interest therein to another person "the farmee") in consideration of the farmee's agreement to incur exploration and development expenses on that property, the proceeds of disposition to the farmor and the acquisition cost to the farmee of the resource property will be viewed as being nil.       ... This would result in an addition or reduction to the respective person's resource pools, as the case may be. ...

Our understanding of the salient provisions of the reclamation Act is as follows: 1.      ... Paragraph 18(1)(m) of the Act provides that no deduction shall be made in respect of "...any amount... paid or payable by virtue of an obligation imposed by statue to (i)     Her Majesty in right of... a province, (ii)     an agent of Her Majesty in right of... a province, or (iii)     a corporation, commission or association that is controlled by Her Majesty in right of... a province or by an agent of Her Majesty in right of... a province as a royalty, tax..., lease rental or bonus or as an amount, however described, that may reasonable be regarded as being in relation to (iv)     the acquisition, development or ownership of a Canadian resource property, or (v)     the production in Canada of... (B) metal or minerals... from a mineral resource in Canada..." In order to be deductible such that paragraph 18(1)(m) of the Act did not apply, payments to the Fund would need to be something other than disguised royalties, taxes, lease rentals or bonuses.  ...

22 November 1990 Ministerial Correspondence 73984 F- CCA Class on Railway Tracks and Spur Line Unedited CRA Tags 1104(5), 1205   November 22, 1990 Special Audits Division Resource Industries E.H. ... Subparagraph 1104(5) of the Regulations      The provisions of Regulation 1104(5) which would be relevant are as follows:      For purposes of Class 10 in Schedule II, "income from a mine", or any expression referring to income from a mine, includes income reasonably attributable to (a)     the processing of (i)     ore, other than iron ore or tar sands ore, from a mineral resource owned by the taxpayer to any sage that is not beyond the prime metal stage or its equivalent, (c)     the transportation of (i)       output, other than iron ore or tar sands ore, from a mineral resource owned by the taxpayer that has been processed by him to any stage that is not beyond the prime metal stage or its equivalent, to the extent that such transportation is effected through the use of property of the taxpayer that is included in Class 10 in Schedule II by virtue of paragraph (m) thereof or that would be so included if that paragraph were read without reference to subparagraph (v) thereof. 6.      ... A/DirectorBilingual Services and Resource Industries DivisionRulings Directorate ...

" Page 5 9.     21(1)(b) 10.      Line 17 (paragraph l3)- it may be clearer to use the words "divided by" in place of "over. ... " 13.     Line 17 (paragraph 26)- The words "... taxation years and... ... " 27.     The various references in the bulletin to resource "expenditures" should be reworded as resource "expenses" in order to be consistent with the language used in the Act.  ...