Search - ”资源化利用" resource

In the 1989 referral the Committee noted that the successored resource pools were attributed primarily to the mining activity which was not the subject of the successor corporation election. ... Assuming that the shares of Corporation A are to be sold without the resource pools, it becomes apparent that the transfer of the mining business into Newsub is the means by which Corporation A can avail itself of the successor election in order to transfer the resource pools to the sister corporation. ... The question and answer was reviewed by John Kurrant, Oil & Gas Specialist on June 12 and he said that he does not have any concerns. ...

7 April 1991 Income Tax Severed Letter- Amending Joint Exploration Corporation Renouncements Unedited CRA Tags 66 OIL & GAS ISSUE REPORT O&G 09 RE: Audit Policy TITLE: Amending Joint Exploration Corporation Renouncements LEGISLATION: Sec 66's (10), (10.1), (10.2) and (10.3) ISSUES: Pursuant to a joint exploration corporation (JEC) agreement certain expenditures are renounced to a shareholder corporation. ... TAX IMPLICATIONS: 1) To preclude the JEC from subsequently renouncing the reclassified expenditures or claiming them again as a deduction (double claim). 2) To ensure that the reclassified amounts are included in the correct resources pools of a shareholder corporation and in the proper year. DEPARTMENT'S POLICY: The Department is prepared to adjust the resource pools of a shareholder corporation in the year(s) the reclassifications were made to the JEC. ...

Reasons: Based upon the facts of the situation and a written opinion received from Natural Resources Canada. ... "investment tax credit" " has the meaning assigned to that expression by subsection 127(9) of the Act. "mineral resource" has the meaning assigned to that term by subsection 248(1) of the Act. ...

You describe a termination clause as one which provides that the agreement will terminate on the occurrence of certain events such as upon (i) the appointment of a trustee, receiver or liquidator following a bankruptcy, insolvency, liquidation or dissolution of the resource company, (ii) an act of God, (iii) the enactment of any law or regulation that would prevent the resource company from renouncing expenses in favour of the investor, and (iv) the receipt by the resource company of an opinion from qualified experts that its exploration program will not yield the described results, and so on. For purposes of rendering our comments herein, we are obliged to add that we would expect that the termination clause would also provide that the occurrence of termination would not have any effect on any action taken or performed by the resource company before such occurrence; and would not negate the obligation of the resource company (1) to renounce the maximum amount of expenses that it would otherwise be entitled to renounce by reason of the expenses being incurred before the occurrence, (2) to issue shares pursuant to the agreement, or (3) to flow-through any incentive payments to which the resource company would otherwise be entitled. ... Paragraph 6202.1(1)(b) Your stated opinion is that "... shares issued pursuant to a flow-through share agreement which contains a termination clause would be flow-through shares as defined by paragraph 66(15)(d.1), notwithstanding that the agreement could terminate prior to the fulfillment of the conditions in that paragraph. ...

1 May 1988 Income Tax Severed Letter HEAD OFFICE Rulings Directorate Resource Industries Section J.T. ... Rowntree & Co. Ltd., [1945] 1 All E.R. 482; Dupuis Frères Ltd. v. ... SAVAGE Chief Resource Industries Section Bilingual Services and Resource Industries Division Rulings Directorate ...

In this case, Partner A's ACB of its partnership interest at the time of admission of Partner 8 would be $10 million for purposes of allocating income, losses or C0GPE, as the case may be, not $ nil as suggested in the hypothetical situation. ... Carved-out property is defined at subsection 209(1) of the Act generally as a Canadian resource property as this term is defined at paragraph 66(l5)(c) of the Act. ... Yours truly, Section Chief Resource Industries Section Bilingual Services and Resource Industries Division Rulings Directorate ...

20 September 1989 Income Tax Severed Letter AC32244- Existence of a Joint Venture or Partnership September 20, 1989 LEGAL SERVICES- TAXATION RULINGS DIRECTORATE Resource Industries Attn: C.T.A. MacNab Section General Counsel John Shaw 957-8968 3-2244 24(1) We enclose a copy an adverse decision- D & B Oilfield Contracting Ltd. v. ...

Several years ago, each partner transferred resource properties and related depreciable properties to the partnership and elected under subsection 97(2) in respect to the transfer. ... The partners used the money to pay the purchase price of the resource properties. ... Director Reorganizations & Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch ...

Paragraph 1(a)(ii) of Article III of the present Canada-United Kingdom Income Tax Convention which entered into force on December 17, 1980, states: "the term "United Kingdom" means Great Britain and Northern Ireland, including any area outside the territorial sea of the United Kingdom which in accordance with international tax law has been or may be hereafter designated, under the laws of the United Kingdom concerning the Continental Shelf, as an area within which the rights of the United Kingdom with respect to the sea-bed and sub-soil and their natural resources may be exercised." Paragraph 1(a) of Article 2 of the former Canada-United Kingdom Income Tax Agreement states that: "the term "United Kingdom" means Great Britain and Northern Ireland, including any area outside the territorial waters of the United Kingdom which has been designated, under the laws of the United Kingdom concerning the Continental Shelf, as an area within which The rights of the United Kingdom with respect to the sea-bed and sub-soil and their natural resources may be exercised;" While both the Convention and the Agreement contain clauses which permit an extension of these treaties to any ".. territory for whose international relation either of the Contracting Governments is responsible... ...

14 September 1989 Income Tax Severed Letter 5-8421- Agreement in writing—flow-through shares Unedited CRA Tags 66(15)(d.1) Dear Sirs: This is in reply to your letter dated July 19, 1989, in which you requested our opinion regarding our interpretation of paragraph 66(15)(d.1) of the Act as it related to the issue of whether resource expenditures incurred prior to the date on which an agreement is entered into in writing can be renounced pursuant to the flow-through share provisions of the Act. Your Views For this purpose you provided us with your views on the matter which are as follows: It is your view the words used in the preamble of paragraph 66(15)(d.1) of the Act, i.e. “... issued to a person pursuant to an agreement in writing entered into... after February 1986,...”, indicate two (2) actions which must occur in order for a share to qualify as a flow-through share. ... Paragraph 66(15)(d.1) of the Act requires that this “written agreement” exist between the principal- business corporation and the purchaser of the flow-through share prior to the date the resource expenditures are incurred. ...