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The Equity Commitment is the portion of an Investor's investment which he or she will be required to pay from his or her own resources. ... Delete the period at the end of paragraph 13 in "Proposed Transactions" and replace it with the following: ", provided that the Partnership is otherwise able to make such investment, having regard to any investment, regulatory or legislative restrictions, and subject to the General Partner's discretion to vary the requirement if necessary in the circumstances. ... Yours truly, XXXXXXXXXX for Director Resources, Partnerships and Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch ...

Our understanding of the objective of the amendments to subparagraphs 66.2(5)(a)(iv), 66.4(5)(a)(ii) and 53(1)(e)(vii.1) is to allow a taxpayer to have an option to capitalize his share of a partnership's Canadian development expenses and Canadian oil and gas property expenses as a part of the adjusted cost base of his partnership interest in a situation wherein he can not utilize the deductions with respect to such expenses or he does not want to carry forward such resource pools beyond the time he disposes of his partnership interest. 2. We have been told by Drew Burnett of Current Amendment that the Department of Finance decided many years ago that the resource expenses should be deductible only at the level of partners and not at the level of partnership. ... 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. ...

Bonus consideration payments are a disposition of a Canadian Resource Property. ... & 4. Payments of the consideration for a petroleum and natural gas lease, as described in points 3 and 4 of your memorandum, should be treated in the same way as payments of bonus consideration as described in 1 above. 5. ...

Paragraph 6202(b) of the Regulations concerning prescribed shares for the purposes of the old flow-through share legislation ("... is a prescribed share if... a member of the related issuing group provides... any form of guarantee, security or similar indemnity with respect to the share... ... XXX At pages 829 and 830 of the 1984 Canadian Tax Foundation Conference Report (copy attached), Revenue Canada stated that the provisions of an indemnity whereunder a company agreed to indemnify the subscriber for any liability that might be incurred as a result of the resource company incurring the requisite expenses as agent for the subscriber would not generally result in the share being a prescribed share within the meaning of Section 6202 of the then draft Regulations. ...

Bonus consideration payments are a disposition of a Canadian Resource Property. ... & 4. Payments of the consideration for a petroleum and natural gas lease, as described in points 3 and 4 of your memorandum, should be treated in the same way as payments of bonus consideration as described in 1 above. 5. ...

7 January 1987 Income Tax Severed Letter CURRENT AMENDMENTS DATE January 7, 1987 FROM- Rulings Directorate Resource Industries Section Allan B. ... The investor's mining exploration depletion base is then reduced by the same amount of assistance (i.e. $950,000 minus $50,000 = $900,000 X 33 1/3%). ...

7 February 1991 Income Tax Severed Letter- Review of the General Anti-avoidance Rule Course Material- Lesson #3 Unedited CRA Tags 245(2) Subject: Review of The General Anti-Avoidance Rule Course Material- Lesson # 3 We have now had a chance to complete a technical review of the course material titled “The General Anti-Avoidance Rule”. ... Proposed subsection 66(10) will prevent the “warehousing” of resource expenditures incurred prior to the existence of a flow- through share agreement. ... Normally as a matter of Departmental policy, an apportionment of the resource pool costs between the mining properties and the oil and gas properties would be acceptable. ...

PRINCIPAL ISSUES: Change in facts to Ruling 2005-016295 []. POSITION: Accepted. ... XXXXXXXXXX 2006-021258 XXXXXXXXXX, 2006 Dear XXXXXXXXXX: Subject: XXXXXXXXXX—Change in Facts to Advance Income Tax Ruling #2005-016295 [] (the “Ruling”) This is in reply to your facsimile of XXXXXXXXXX wherein you requested certain amendments to the Ruling that was issued to the above-noted taxpayer on XXXXXXXXXX. ... Yours truly, XXXXXXXXXX Industry Sector Specialist Corporate Reorganizations Section II Reorganizations and Resources Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

Grisé Human Resources Branch 957-2059 2000-001117 Fiscal Periods This is in reply to your E-mail of March 1, 2000 requesting our comments on the fiscal period of a business. ... Ron Boicey from the Technical Applications and Valuations Division of the Verification, Enforcement & Compliance Research Branch. ... Ron Boicey Technical Applications Section Verification, Enforcement & Compliance Research Branch?? ...

Ryan: XXXX The Canadian Income Tax Act (the "Act") provides under section 212(1) that non-residents of Canada are subject to Canadian income tax at a 25% rate "... if a person resident in Canada... ... Section 212(13.2) of the Act provides: "For the purposes of this Part, where in a taxation year (a) a non-resident person whose business was carried on principally in Canada, or (b) a non-resident person who (i) manufactures or processes goods in Canada, (ii) operates an oil or gas well in Canada, or (iii) extracts minerals from a mineral resource in Canada pays or credits an amount (other than an amount to which subsection (13) applies) to another non-resident person, he shall be deemed, in respect of the portion of that amount that was deductible in computing his taxable income earned in Canada for any taxation year, to be a person resident in Canada. ... Article XII of that treaty provided that with respect to the interest prepayment the recipient, XXXX was "... exempt from all taxes imposed by Canada. ...