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3 June 1991 Income Tax Severed Letter 91M06315 F- Flow-through Shares- Prescribed Shares Unedited CRA Tags 6202.1(1)(c), 66(12.73), 6202.1 Question 20.      ... Answer 20.     We reiterate our answer to this question which was asked in Question 7 at the 1990 Roundtable (Canadian Petroleum Tax Journal, Fall 1990, page 141):      Provided the issuer agrees to pay damages to the subscriber only to the extent of any additional tax payable by the subscriber as a consequence of a reduction of the expected tax deductions pursuant to subsection 66(12.73) of the Income Tax Act, it is our view that such an indemnity would not cause any issued shares to be prescribed shares within the meaning of section 6202.1 of the Regulations.       ... If there is any concern about this answer in a particular fact situation, the Resource Industries Section of Rulings would be pleased to examine a ruling request on the matter. ...

19 January 1993 Income Tax Severed Letter 9301246- Structuring Gold Mining Operations NOTES FOR PRESENTATION ON FINANCING GOLD MINING OPERATIONS INDUSTRY EXCHANGE OF INFORMATION MEETING—GOLD MINING CANADA—UNITED STATES OTTAWA—JANUARY 19, 1993 PRESENTED BY:JOHN CHANFILE # 930124 ACTING SECTION CHIEF RESOURCE INDUSTRIES SECTION MANUFACTURING INDUSTRIES, PARTNERSHIPS AND TRUSTS DIVISION RULINGS DIRECTORATE ON BEHALF OF THE RESOURCE INDUSTRIES SECTION, RULINGS DIRECTORATE, I WOULD LIKE TO THANK MR. ... REVENUE CANADA WILL TREAT WIDESPREAD FARMOUTS IN WHICH THE FARMEE RECEIVES UNPROVEN RESOURCE PROPERTY OF THE FARMOR AS NOT GIVING RISE TO PROCEEDS OF DISPOSITION IRRESPECTIVE OF WHETHER OR NOT THE UNPROVEN RESOURCE PROPERTY IS CONTIGUOUS TO THE PROPERTY BEING EXPLORED OR DEVELOPED BY THE FARMEE. ... -END- ************************************************************ ***** ...

Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle du ministère. 7- 3733 Frank Gillman 957-9768 Current Amendments & Rulings Directorate Regulations Divisions Resource Industries Legislative Affairs Directorate Section Frank Gillman Attention: B. ... The Queen, Dube, J stated "... The Act (Income Tax Act) must be construed according to its own definitions, or the ordinary meaning of the words used, or the common usage by the people in the relevant industry. ...

14 June 1983 Income Tax Severed Letter 95-5136 F Dear Sirs: RE:     Trust income calculation under the Income Tax Act ("ITA") This is in reply to your letter of May 25, 1983 in which you asked for our views on three issues related to the calculation of trust income. (1) As stated in our May 9, 1983 letter to you, an amount cannot be payable to a trust beneficiary, within the meaning of subsection 104(24) of the ITA, if it has already been paid as a tax. ... As noted in (2) above, production royalties are included in resource profits eligible for the resource allowance under paragraph 20(1)(v.1) of the ITA, by virtue of paragraph 1210(1)(c) of the ITR. ... The trust is not required to deduct the paragraph 104(6)(b) amount in respect of distributions to beneficiaries in calculating its resource profits eligible for the resource allowance. ...

White 957-8585 February 24, 1989 We apologize for the delay in replying to your memorandum of May 26, 1988, but we were awaiting a relevant memorandum from Current Amendments & Regulations Division before replying. ... " We are dealing in these cases with an Industrial Mineral Mine not a mineral resource. ... Director Bilingual Services and Resource Industries Division Rulings Directorate ...

14 December 1988 Income Tax Severed Letter 95-6879 F Dear Sirs: RE:     Subsection 55(3) of the Income Tax Act This is in reply to your letter of October 18, 1988, whereby you request our comments concerning the application of subsection 55(3) of the Act in the following situation. 1. ... YZ-Co.'s assets also consist Of current operating assets, a receivable from Y-Co. and foreign resource properties located in a different jurisdiction than the foreign resource properties of Z-Co. ... More specifically, given the facts above, is it appropriate to consider that the types of property held by Z-Co. do not include the foreign resource properties and related tangibles of Z-Co. plus the investment in YZ-Co. as separate types of property, but rather include foreign resource properties and tangibles as only one type (business assets)? ...

5 May 1989 Income Tax Severed Letter 5-7814- [Subsection 66.8(2) of the Income Tax Act] Unedited CRA Tags 96, 245(2), 66, 66.1, 66.2, 66.4, 66.8 REVENUE CANADA TAXATION MEMORANDUM DATE May 5, 1989 TO Current Amendments & Regulations Division Bill Bryson Acting Director FROM Rulings Directorate Resource Industries Section Frank S. ...

Mail Control & OPRU Taxpayer's file XXXX Your letter of October 10, 1985, regarding the taxation of oil royalties has been forwarded to me for response. ... The resource allowance is a deduction in computing income equal to 25% of certain resource profits calculated as set forth in the Income Tax Regulations. Although the Regulations previously included all royalties in resource profits upon which the resource allowance was computed, in 1981 the Regulations were amended to exclude certain royalties from the resource profits of a taxpayer. ...

To illustrate your understanding, you presented the following hypothetical example: Taxable income $ X Less non-deductible items: Crown royalties- S.18(1)(m) $ X Mineral Taxes- S.18(1)(m) X Crown lease rentals- S.18(1)(m) X Phantom income- S.69(6) tax and (7) X Petroleum and gas revenue tax X Incremental oil revenue disallowed X Interest and penalties X Political donations-S.18(1)(l) X Other non-deductible expenses X X---- X Less current income taxes: Federal (net of investment tax credit) X Provincial (after provincial credits and rebates, including Alberta royalty tax deduction and Alberta royalty tax credit) X X---- X Less dividends paid X-- X Add: Half of capital gains (net of capital losses) X Dividends received X Taxable incremental oil revenue-S.81(1)(r) X Resource allowance-S.20(1)(v.l) X Depletion Allowance-S.65 X X---- Post-1971 income earned or realized $ X reasonably attributable to capital gain === The Department's views on the principles employed in the calculation of income earned or realized after 1971 ("safe income") were stated at the 1981 Canadian Tax Foundation and are published in the 1981 Conference Report. ...

• Is this the intended result? • If this was not the intent, are any steps being taken to amend the definition or administer the law differently? ... Since resource pools are neither Canadian resource properties nor foreign resource properties, no value need be assigned to them for these purposes. ... Paragraph 66(15)(e) defines foreign exploration and development expenses to include the ".... cost to him of any foreign resource property acquired by him,... ...