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22 February 1991 Income Tax Severed Letter February 22, 1991 Calgary District Office Resource Industries Section Cliff Colbourne 957-9768 Attention: John Kurrant Oil & Gas Industry Specialist 7-910384 "Stacking" of JEC's Your memorandum of February 5, 1991 asked for confirmation of the Department's position in regards to the renunciation by a joint exploration corporation ("JEC") of Canadian exploration expenses ("CEE") pursuant to subsection 66(10.1) in circumstances where such CEE had previously been renounced to it under the same provision of the Act. ... Yours truly, Section Chief Resource Industries Section Bilingual Services and Resource Industries Division Rulings Directorate 000069 ...

Subsections 1100(24), (25), (26), & (27) of the Regulations. 3. Class 34 Pamphlet published by Energy, Mines and Resources Canada. ...

19 April 1990 Income Tax Severed Letter AC80358- Canadian Exploration Expense of a New Mine DATE April 19, 1990 TO Appeals & Referrals Division FROM Rulings Directorate Appeals Branch DE Resource Industries Section Mr. ... According to the technical notes the change in the wording from mineral resource to new mine results in mine development expenses incurred in bringing a new mine in a mineral resource into production may qualify as Canadian Exploration Expense even though there may have been production from the mineral resource by another mine. ... Section Chief Resource Industries Section Bilingual Services and Resource Industries Division Rulings Directorate ...

Subsections 1100(24), (25), (26), & (27) of the Regulations. 3. Class 34 Pamphlet published by Energy, Mines and Resources Canada. ...

Bert Titcomb Energy Efficiency Division Efficiency & Alternative Energy 920346 Technology Branch W.P. Giglich Energy Mines and Resources Canada (613) 957-2102 580 Booth Street Ottawa, Ontario K1A 0E4 March 12, 1992 Dear Sirs: Re: Class 34 This is in response to your fax letters of January 30 and February 6, 1992 wherein you request our views concerning your draft letters respecting eligibility of property for certification under class 34. Our comments regarding your draft letters follow: * The second sentence of paragraph 3 of your 24(1) letters states "Revenue Canada is responsible for the administration of the Income Tax Act and Regulations, including all non-technical criteria for inclusion of property in Class 34". ...

Bert Titcomb Energy Efficiency Division Efficiency & Alternative Energy 920346 Technology Branch W.P. Giglich Energy Mines and Resources Canada (613) 957-2102 580 Booth Street Ottawa, Ontario K1A 0E4 March 12, 1992 Dear Sirs: Re: Class 34 This is in response to your fax letters of January 30 and February 6, 1992 wherein you request our views concerning your draft letters respecting eligibility of property for certification under class 34. Our comments regarding your draft letters follow: * The second sentence of paragraph 3 of your 24(1) letters states "Revenue Canada is responsible for the administration of the Income Tax Act and Regulations, including all non-technical criteria for inclusion of property in Class 34". ...

Hydro portion 50---- Total $500 ==== Information obtained from the Department of Energy, Mines and Resources Canada shows the allocation as follows: Pre-April 1, 1987----------------- Federal Provincial B.C. ... Hydro Natural Gas Conversion Grants with Peter Reilly-Roe, Director of Policy Analysis with the Department of Energy Mines and Resources (E.M.R.). ... Savage Chief Resource Industries Section Bilingual Services and Resource Industries Section Rulings Directorate ...

Paragraph 2 of Article VI of the Convention clearly defines the term real property to include "... rights to explore for or to exploit mineral deposits, sources and other natural resources and rights to amounts computed by reference to the amount or value of production from such resources (overriding royalties). In addition, paragraph 1 of Article VI of the Convention indicates it was the intention of the negotiators to include resource properties in that article when they added the word "or other natural resources" to the wording of the OECD Model. Accordingly, it is our view that Canada has maintained its right under Article VI of the Convention to tax income from resource property whether the non-resident has a permanent establishment or not in Canada to the extent that such amounts are included in the income of the non-resident by virtue of section 115 of the Income Tax Act (the "Act"). ...

Our Comments We offer the following comments related to the above questions: 1) The RDIA states that a "facility" means "the structures, machinery and equipment that constitute the necessary components of a M & P operation, other than an initial processing operation in a resource-based industry". ... Generally, all pulp mills are considered to be initial processing operations in a resource-based industry and thus do not qualify. ... b) do the activities constitute an initial processing operation in a resource-based industry? ...

Bert Titcomb Energy Efficiency Division Efficiency & Alternative Energy 920346 Technology Branch W.P. Giglich Energy Mines and Resources Canada (613) 957-102 580 Booth Street Ottawa, Ontario K1A 0E4 March 12, 1992 Dear Sirs: Re: Class 34 This is in response to your fax letters of January 30 and February 6, 1992 wherein you request our views concerning your draft letters respecting eligibility of property for certification under class 34. Our comments regarding your draft letters follow: • The second sentence of paragraph 3 of your XXX letters states “Revenue Canada is responsible for the administration of the Income Tax Act and Regulations, including all non-technical criteria for inclusion of property in Class 34”. ...