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Paragraph 115(4)(b) specifically states that the deeming provision is for "... purposes only of computing the non-resident person's income earned in Canada for the year... ... We recommend that the words " proportionately as to 50% or more" be substituted thereto. ... Director Bilingual Services and Resource Industries Division Rulings Directorate ...

1 November 1991 Income Tax Severed Letter 91M11265 F- Canadian Exploration Expenses Unedited CRA Tags 66.1(6)(a) QUESTION 4.      ... ANSWER 4.        The Department's long-standing position is that net operating expenses would be eligible for inclusion in CEE provided that they are incurred for the purpose specified in subparagraph 66.1(6)(a)(iii.1) and before the commencement of commercial production of the new mine. ... Net profit, if any, would be eligible for inclusion in resource profits under Regulation 1204. ...

Answer 29.       The Department's long-standing position is that net operating expenses would be eligible for inclusion in CEE provided that they are incurred for the purpose specified in subparagraph 66.1(6)(a)(iii.1) and before the commencement of commercial production of the new mine. ... Net profit, if any, would be eligible for inclusion in resource profits under Regulation 1204. ... However, the pre-production revenue would not be eligible for inclusion in resource profits under Regulation 1204. ...

Black & Decker Manufacturing Company, Limited ((1975) 1S.C.R. 411), that an amalgamated company continues the business of its predecessors. ... This position has been reviewed with the Audit Applications and Industry Studies Sections of Policy & Systems Branch. Chief Mines, Oil & Forest Industries Section Specialty Corporations Rulings Division Corporate Rulings Directorate Legislation Branch c.c. ...

George Thompson & Company, Limited (1927), 13 TC 83. Therein, Mr. ... XXX Other Gary Kwan requested our comments with respect to a hypothetical situation described at page 3 of the Calgary D.O. memorandum wherein an unintended benefit, i.e., enhanced resource allowance deduction, was perceived to have accrued to a taxpayer who maintains a single Class 10 pool of assets comprising assets used to earn resource profits and assets which are not used to earn resource profits. ... Since CCA claims on assets used to earn resource profits reduce resource profits under the provisions of Regulation 1204(1), reduction of the U.C.C. of these assets results in reduction of the total CCA claims which would eventually reduce resource profits, thereby achieving the perceived benefit. ...

Subject to treaty provisions, all royalties received directly by a non-resident who is not carrying on a resource-related business in Canada are considered to be resource royalties for PGRT purposes. ... Therefore a royalty received by a non-resident whose royalty income is only subject to Part XIII Tax is a resource royalty, and no resource allowance under paragraph 82(2)(e) of the PGRT Act is claimable. ... You enquired whether the example on page 6 of the department's January 1983 publication 'Notice to Petroleum & Gas Revenue Tax Act Taxpayers' is correct in showing production royalties of $500 per month, taxable at 16% and incremental production royalties of $50 per month taxable at 50% for the period January 1 to May 31, 1983. ...

Second, a taxpayer (the farmee) must make expenditures for CEE and not to acquire a resource property. ... What it did do was to pay for a contractual right to acquire an interest in lands on which exploration and drilling had taken place by paying expenses already incurred by Scurry in connection therewith ". ... XXXX Chief Resource Industries Section Rulings Directorate ...

Senecal Resource Industries Section RE: Section 8 B.C. Income Tax Act This is in reply to your memorandum of February 4, 1986, concerning the B. ... Royalty and Deemed Income Rebate which was recently forwarded to us by Provincial & International Relations Division for our consideration and response. ... Savage Chief Resource Industries Section Bilingual Services and Resource Industries Division Rulings Directorate Legislative and Intergovernmental Affairs Branch ...

.: 3-2601 RE: Deduction of expenditures on Scientific Research in the calculation of Resource Profits This is in to your memorandum dated February 16, 1983. We hereby confirm that the reference to scientific research expenditures in our memorandum concerning the treatment of scientific research expenditures for purposes of the calculation of resource profits includes amounts referred to in section 37.1 of the Income Tax Act, Canada. Chief Mines, Oil & Forest Industries Section Specialty Corporations Rulings Division Corporate Rulings Directorate Legislation Branch ...

Prior to this review our argument was that resource properties were not eligible for the "fresh start" rule for the following reasons. ... Paragraph 2 of Article VI provides that the term "real property" includes resource property. ... We have recently been advised by the Department of Finance that the purpose of the passage in the Technical Explanation which reads "... paragraph 9 applies to a gain described in paragraph 1, even though such gain is also income within the meaning of paragraph 3 of Article VI. ...