Search - ”资源化利用" resource

Brooks (613) 957-2097 February 5, 1990 This is in reply to your letter of August 2, 1989, in which you requested our comments as to whether contributions in kind with respect to scientific research and experimental development (“SR & ED”) could qualify as SR & ED expenditures. ... “Silviculture for Integrated Resource Management” and “Fish-Forestry Interaction Program.” ... With respect to the Silviculture for Integrated Resource management project, it appears that the involvement of 24(1) would be sufficient to have it considered to be a joint participant. ...

14 November 1985 Income Tax Severed Letter RCT 5-8077 F Unedited CRA Tags 55 Dear Sirs: RE:     Section 55 of the Income Tax Act This is in reply to your letter of October 10, 1985 wherein you requested confirmation of your understanding of the computation of "income earned or realized... after 1971" for the purposes of subsection 55(2) of the Act. 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) and (7) X Petroleum and gas revenue tax X Incremental oil revenue tax X Interest and penalties disallowed X Political donations  X Club dues and recreational facilities- S.18(1)(1) 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.1) X Depletion Allowance-S.65 X X Post-1971 income earned or realized reasonably attributable to capital gain  $X The Department's view 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. ... However, viewing your example in isolation, we agree with the results of your calculation subject to the following:-     losses incurred after 1971 would be deducted in determining the amount of a gain attributable to "safe income"-     dividends received will be included in the "safe income" of the recipient if received out of the "safe income" of a subsidiary.-     the addition of one half of the difference between capital gains and capital losses is made for resident corporations which are not private. ...

11 June 1985 Income Tax Severed Letter RCT 5-7592 F Unedited CRA Tags 55 Dear Sirs: RE:     Section 55 of the Income Tax Act This is in reply to your letter of April 4, 1985 wherein you requested confirmation of your understanding of the computation of "income earned or realized... after 1971" for the purposes of subsection 55(2) of the Act. To illustrate your understanding, you presented the following hypothetical example: Post-1971 taxable income to date of transaction XX Add: Charitable donations deducted XX Dividends deductible under subsection 112(1) XX Losses applied from other years XX XX Equals income for tax purposes XX Add: Inventory allowance under 20(1)(gg) XX Research allowance under 37.1 XX Resource allowance under 20(1)(v.1) XX Depletion allowance under 65(1) XX 1972 and 1973 "exempt" mining income under ITAR(28) XX 1972 to 1974 mining taxes deducted under 20(1)(v) in repsect of mineral ressources (and which are deducted below as part of production taxes paid) XX Net eligible capital amounts (reference 55(5)(b)(iii))XX One-half of the excess of capital gains over capital losses (reference 55(5)(b)(ii)) XX XX XX Deduct: Production taxes paid, including all amounts considered non-deductib considered non-deductible under 18(1)(m) and 1972-1974 deductible amounts added above XX Depletion recoveries under 59(3.3) XX Corporation income taxes assessed/paid XX Charitable donations paid XX Dividends paid  XX Other non-deductible expenses XX XX Post-1971 income earned or realized reasonably attributable to capital gain XX The Department's view on the principles employed in the calculation of income earned or realized after 1971 ("safe income") were expounded at the 1981 Canadian Tax Foundation and are reflected in the 1981 Conference Report. ... However, viewing your example in complete isolation, we would agree with the results of your calculation subject to the following:-     losses incurred after 1971 would be deducted in determining the amount of a gain attributable to "safe income"-     dividends received will be included in the "safe income" of the recipient if received out of the "safe income" of a subsidiary. ...

PRINCIPAL ISSUES: Change in facts to Ruling 2005-015884 []. POSITION: Accepted. ... —Change in Facts to Advance Income Tax Ruling #2005-015884 [] (the “Ruling”) This is in reply to your facsimile letter of XXXXXXXXXX wherein you requested certain amendments to the Ruling that was issued to the above-noted taxpayers on XXXXXXXXXX, 2006. ... Yours truly, XXXXXXXXXX Manager Corporate Reorganizations Section II Reorganizations and Resources Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

—Change in Facts to Advance Income Tax Ruling #2006-018810 [] (the “Ruling”) This is in reply to your request for a minor amendment to the Ruling that was issued to the above-noted taxpayer on XXXXXXXXXX, 2006. ... Yours truly, XXXXXXXXXX Industry Sector Specialist Corporate Reorganizations Section II Reorganizations and Resources Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

Bernard Vézina Staff Officer Anadromous Fisheries Resource Allocation Branch------------------------------------- November 18, 1986 Dear Sirs: This is in reply to your letter of September 17, 1986, concerning the tax treatment of amounts received by Maritime salmon fishermen under the "Voluntary Licence Buy-Back Program. ... Our answers, in the order of your questions raised, are as follows: a) & b) As stated in our previous letter to your Department of May 8, 1984, it is our view that the license could be considered as an "eligible capital property" and the relinquishment of fishing privileges thereunder would constitute a disposition of such a property. ...

Barsalo 957-8284 Attention: 19(1) July 24, 1990 Dear Sirs: Re: Prepayment of a debt obligation This is in reply to your letter of june 15, 1990 wherein you requested our opinion on the meaning of the phrase "may not under any circumstances be obliged to pay more than 25% of (...) the principal amount of the obligation" found in subparagraph 212(1)(b)(vii) of the Income Tax Act (the "Act"). ... Yours truly, for Acting Director Bilingual Services and Resource Industries Division Rulings Directorate Legislative and Intergovernmental Affairs Branch ...

Principal Issues: 1. whether amounts are charitable "gifts" 2.whether donors are "investors" 3. whether "investor rules apply to deny film tax credit to producer 4. whether amounts are assistance Position: 1. depends on facts of case 2. yes 3. no if charitable gifts; possibly if not charitable gifts 4. no if charitable gifts; probably if not charitable gifts Reasons: 1. meaning of "gifts" at law 2. definition of "investor" in 125.4(1) is very broad 3. 125.4(4) question of fact whether amounts are deductible in respect of the production 4.12(1)(x) may apply depending on the facts June 5, 2000 SR & ED Directorate Partnerships Section Financial Legislative Application Section Denise Dalphy (613) 957-9231 Attention: Mel Machado, Manager 2000-000820 Canadian Film or Video Production Tax Credit ("PSTC")- Investor/Investment This is in response to your memorandum dated February 10, 2000, where you requested our comments on the application of subsections 125.4(1) and (4) in a particular fact situation. ... " If the amounts paid to XXXXXXXXXX were provided on condition that XXXXXXXXXX give the amounts to the Producer, the amounts would not be "gifts" to XXXXXXXXXX, but would be gifts to the Producer. ... Paul Lynch for Director Resources, Partnerships and Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch * In Nowegijick, the Supreme Court of Canada stated: "The words "in respect of" are, in my opinion, words of the widest possible scope. ...

. • as required by B.C. law, individual parcels may not exceed 520 hectares (approx. 1285 acres); • these consist of arable/non-arable plots containing stated quantities of merchantable timber as established by Ministry timber cruises; • their location, means of accessing, the type of soil and topography, the services available, if any; • the amount spent by the Ministry to date on the parcels' development; and • the amount of the purchase price should the option to purchase be exercised. 4. ... " of a property, other than a timber resource property, that is a timber limit or a right to cut timber from a limit;" 14A. ... As to the intent of the legislation, the "Explanatory Notes" to Bill C-49, given Royal Assent on March 13, 1975 commenting on paragraph 13(21)(d.1) state: "This new provision defines "timber resource property". ...

“Eligible exploration expense” in relation to a mineral resource and hydrocarbons is defined in subsections 5(1) and (2) of the CEIP Regulations. 5. ... The eligible exploration expenses comprise Actual CEE incurred $ 97,000 Operator allowance $97,000 x 3%, say 3,000 $100,000 YOUR QUESTIONS You have asked: 1. ... Dan MacDonald, Energy Mines and Resources with whom the above was informally discussed. ...