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Paragraph 15 With respect to timber properties, this term is too vague and could be construed as including such timber properties as timber limits and cutting rights which may not be timber resource properties for purposes of the Act- see paragraph 13(21)(d.1) for the definition of timber resource properties. ... We recommend that the words " proportionately as to 50% or more" be substituted thereto. ... We suggest that the defined term Canadian resource property be used instead of the words "Canadian mining, oil" at paragraph 15(d) as this would be more explicit to the reader. 4. ...

Consider the following example: Form T100 Total expenses to be incurred $ 1,000,000 Less: Assistance to be kept by the company (0) Expenses to be incurred but not renounced (i.e. prescribed CEDOE) (50,000) Amount to be renounced $ 950,000 Form T101 (Present draft formula) Actual expenses incurred $ 1,000,000 Less: Assistance kept or to be kept by the company (0) Amount renounced (net of prescribed CEDOE) should be $950,000 versus the $1,000,000 figure yielded by the above calculation. ... G) Subsection 66(12.7) of the Act and section 228 of the Regulations provide statutory authority for filing Form T101 where there has been a renunciation of resource expenditures. ... Form T102 Summary I) Subsection 66(12.69) of the Act provides statutory authority for filing Form T102 Summary where there has been a renunciation of resource expenditures to a partnership. ...

SUBJECT: CHANGE IN CONTROL CARRYOVER OF TAX POOLS SECTION: 111(4), 111(5), 111(5.1)] Minister/DM's Office Y.S. 92-3646T Central Records Author Section Chief D.O. (?) ... Bldg. original signed by Pierre Gravelle, Deputy Minister, June 8, 1992 Dear XXX The Honourable Otto Jelinek, Minister of National Revenue, has asked me to reply to your letter of April 15, 1992 concerning an April 13 article in the Financial Post regarding a proposed corporate reorganization involving resource companies. ... In some cases when a taxpayer acquires a particular resource property, tax pools related to specifically defined resource expenses may be claimed but only against income derived from the assets which generated the pools. ...

The definition of a mineral resource (section 248 of the Act), however, remains the same. ... The argument which has been made against this position is that such income should flow into resource profits in order to provide a resource allowance to compensate the operator for the undeductible crown charges. ... Chief, Mines, Oil & Forest Industries Specialty Corporation Rulings Division Corporate Rulings Directorate Legislation Branch c.c. ...

Company a owns a royalty interest in respect of the production from this resource property. ... The royalty constitutes a Canadian resource property Pursuant to subparagraph 66(15)(c)(v) of the Act, 3. ... Cheshire & Burns, Modern Law of Real Property, Thirteenth Edition, states at page 852: "At common law merger results automatically from the union of two estates in the circumstances we have mentioned, and intention does not affect the result. ...

21 August 1991 Income Tax Severed Letter AUDIT PROGRAM DIRECTORATE BILINGUAL SERVICE AND SCIENTIFIC RESEARCH RESOURCES INDUSTRIES Audit section Division A. ... " OUR OPINION Paragraphe 149(1)(d) of the Act provides that "No tax is payable under this Part upon the taxable income of a person for a period when this person was (...) (...) (...) ... Acting Chief Bilingual Services- Section 32 Bilingual Services and Resource Industries Division Rulings Directorate 000184 ...

Position Paper #5- Renunciation of resource expenses incurred prior to entering in an agreement Paragraph 66(15)(d.1) and subsections 66(12.6), 66(12.62) and 66(12.64). ... Position Paper #6- "All or substantially all" rule dealing with salaries/bonuses Regulation 1206(1)- Canadian exploration & development overhead expense (CEDOE) definition, paragraphs (a) and (b) With respect to the issue of whether the "all or substantially all" rule should be strictly interpreted to apply in the situation of a junior resource company with few employees (who perform a multitude of tasks spending less then 90, of their time directly on exploration activities) to classify the salaries of such employees as CEDOE, it is our view, unless all or substantially "i all (ie- 90% or more) of the duties of a person employed by a taxpayer, whether or not a junior resource company, are directed toward exploration or development activities, the entire salary, wages or other remuneration paid the person (to the extent the salary, etc. is a Canadian exploration expense (CEE) or a Canadian development expense (CDE)) is CEDOE. ... Position Paper # 12- Classification of oil and gas wells Subparagraphs 66.1(a)(ii.1) and 66.2(5)(a)(i) and subsection 66.1(9) 1. ...

6 September 1984 Income Tax Severed Letter RCT 5-6456 F Unedited CRA Tags 85(1.1) Dear Sirs: RE:     Application of Subsection 85(1.1) after February 15, 1984 This is in reply to your request for our opinion on the application of subsection 85(1.1) of the Income Tax Act to the transfer of a resource property to a new corporation pursuant to subsection 85(1), followed by the wind-up of the new corporation into its parent utilizing subsection 88(1). ...

29 August 1989 Income Tax Severed Letter AC58509- Deductibility of Donations as Business Expenses To: Bilingual Services and Resource Industries Division Carole Gouin-Toussaint Dirctor From: Resource Industries Section John Shaw 957-8509 Subject: 24(1) This is briefing memorandum for our meeting to be held August 30, 1989 with the representatives of 24(1). ... " 21(1)(b) 24(1) decisions in Olympia Floor & Wall Tile (Quebec) Ltée. 70 DTC 6085 and Impenco Ltd. v. ... Section Chief Resource Industries Section Bilingual Services and Resource Industries Division Rulings Directorate ...

Production from the Transferred Resource Properties, for purposes of this example, would have the effect of decreasing the value of such properties over time. 3. ... Therefore, income attributable to the production from or sale of the Transferred Resource Properties would not attribute to such gain. ... Read's remarks at the 1988 Tax Conference it is the Department's "... fundamental view that the ability to make a designation under paragraph 55(5)(f) does not relieve the dividend recipient of the onus imposed by the self-assessment system to report as a gain its best estimate of the amount of the dividend in excess of safe income. ...