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16 May 1983 Income Tax Severed Letter 7-2462- [Part XII of the Income Tax Regulations ("ITR") — Royalty Trusts — Reporting of resource income and allowances] DATE: May 16, 1983 TO- COMPLIANCE DIRECTORATE Audit Programs Division FROM- CORPORATE RULINGS DIRECTORATE J.C. ... McDonald Estate and Trust Group RE: Part XII of the Income Tax Regulations ("ITR") Royalty Trusts Reporting of resource income and allowances A correction is required to our memorandum of April 29, 1983, a copy of which is attached. ... Chief Mines, Oil & Forest Industries Section Specialty Corporations Rulings Division Corporate Rulings Directorate Legislation Branch Attachment ...

28 November 1989 Income Tax Severed Letter AC58940- Diamond Deposits — Mineral Resource November 28, 1989 Dear Sirs: Re: Diamond Deposits- Mineral Resource We are writing in reply to your letter dated October 19, 1989, in which you requested certification that any diamond deposits discovered in kimberlite pipes as a result of the 24(1) would qualify as a mineral resource as defined in subsection 248(1) of the Income Tax Act (the "Act"). ... Consequently, we are of the opinion that the diamond deposits would qualify as a mineral resource under subparagraph (d)(i) of the definition in subsection 248(1) of the Act. Yours truly, Section Chief Resource Industries Section Bilingual Services and Resource Industries Division Rulings Directorate ...

18 March 1983 Income Tax Severed Letter 5-0057- [(1) Gross & Net Royalty Trust/(2) Reporting of Resource Income and Allowances] DATE: March 18, 1983 TO- Corporate Rulings Division FROM- Audit Programs Division Estate and Trust Group T. ... Carsley RE: (1) Gross & Net Royalty Trust (2) Reporting of Resource Income and Allowances We refer to the attached memoranda at March 8 and 15 concerning resource income and resource allowance. ...

1 September 1992 Income Tax Severed Letter 9225591- Finished Goods in the Resource Industries ITC/M & P Unedited CRA Tags 127(11)(b)(i), 125.1(3)(b), Reg. 5202 REVENUE CANADA FORESTRY TAX CONFERENCE PRESENTATION BY RULINGS "FINISHED GOODS" FOR ITC AND M&P PURPOSES After a detailed study conducted during 1991, supported by a written opinion from the Department of Justice ("Justice"), Rulings adopted the view that the products of the extractive industries, such as the logs (the felled trees) from logging, would not constitute "finished goods" referred to in subparagraph 127(11)(b)(i) of the Income Tax Act and paragraph (d) of the definition of "qualified activities" in section 5202 of the Income Tax Regulations for purposes of determining a taxpayer's investment tax credits ("ITC") and manufacturing and processing ("M&P") profits. ... Prepared by:John Chan Date: September 1, 1992 File #: 7-922559 Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information ...

30 October 1989 Income Tax Severed Letter ACC8625- Eligibility of Diamond Deposits as Mineral Resources G.I. White 957-8585 Director General Tax Policy Analysis Division Energy, Mines & Resources Canada Room 706, 580 Booth Street Ottawa, Ontario K1A 0E4 Attention: Mr. ... Schell Director Mining Tax Legislation- Interpretation Division October 30, 1989 Dear Sirs: Re: 24(1) Mineral Resource Subsection 248(1) of the Income Tax Act We are writing to request your certification that diamond deposits occuring in kimberlite pipes is a mineral resource as that term is defined under subparagraph (d)(i) of the definition in subsection 248(1) of the Income Tax Act. ...

1 November 1991 Income Tax Severed Letter 91M11263 F- Resource Profits QUESTION 2.        ... These profits qualify for inclusion in "resource profits" under subsection 1204(1) of the Income Tax Regulations.     ... ANSWER 2.        It is our view that Regulation 1204(1) permits the computation of resource profits by reference to the unrealized price of the intermediate product.  ...

1 November 1991 Income Tax Severed Letter 91M11272 F- Mineral Resource QUESTION 7.        A mineral deposit of a taxpayer has been certified by Energy Mines and Resources Canada (EMR) as a "mineral resource" pursuant to subparagraph (d)(i) of the definition of mineral resource in subsection 248(1) of the Act. ... ANSWER 7.        It is our view that a mineral deposit that has been certified as a mineral resource by EMR under the definition of mineral resource in subsection 248(1) of the Act would not cease to be a mineral resource solely by virtue of the change of ownership of the mineral deposit. ...

5 February 1990 Income Tax Severed Letter AC00322- Resource Allowance- Reimbursement by Taxpayer Unedited CRA Tags 80.2 File Resource Industries Section Allan B. ... (i) his resource profits for the year... computed as if no amount were deducted in computing those resource profits (A) in respect of a rental or royalty paid or payable by the taxpayer (other than...a production royalty)...exceeds the aggregate of (ii)... ... Senecal to 24(1) (copy attached). 24(1) 23 Section Chief Resource Industries Section Bilingual Services & Resource Industries Division Document Disclosed Pursuant to the Access to Information Act Document Divulgué en vertu de la loi sur l'accès à l'information ...

12 June 1989 Income Tax Severed Letter AC58170- Small Business Deduction and Resource Allowance 5-8170 Allan B. ... Whether recaptured capital cost allowance is included in the calculation of the company's resource allowance. ... Chief Resource Industries Section Bilingual Services & Resource Industries Division Rulings Directorate ...

4 May 1989 Income Tax Severed Letter 57814 F- Resource Expense of Limited Partnership Unedited CRA Tags 66.8(2)   95-7814 Current Amendments &                    Rulings Directorate   Regulations Division                  Resource Industries                                          Section B. ...