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(Hiram Walker & Sons Limited v The Corporation of the Town of Walkerville 1933 SCR 247) (d) tuns and vats used in the brewing industry were machinery. ... (IRC v Barclay Curle & Co. Ltd., 1969 all. E.R. 732) Comments: We agree that the convertor is property that is a structure that is manufacturing or processing machinery or equipment as described in paragraph (a) of Class 8. ... Chief, Resource Industries Section Bilingual Services & Resource Industries Division Rulings Directorate Legislative and Intergovernmental Affairs Branch ...

18 November 1982 Income Tax Severed Letter RCT 5-3706 F Unedited CRA Tags 85(1), 98(5) Dear Sirs: RE:     Transfers of resource partnership interests to corporations under subsection 85(1) of the Income Tax Act This is in reply to your letter of January 19, 1982 in which you requested clarification of the Department's position on subsection 85(1) rollovers of resource partnership interests to corporations. ... Depending on the facts of the case, we would view this transaction as being in substance either: a) A sale of resource assets at fair market value by the partnership for shares of the transferor, followed by a distribution of the shares to the partners on a winding up of the partnership; or b) A wind-up of the partnership with a distribution of the partnership assets to the partners at fair market value, followed by a sale of assets by the partners to the purchaser corporation at the same value. c.c. ...

Resource Profits A. Settlements Paid 24(1) In Commissioners of Taxation v. ... " Since Part XII of the Regulations, viz., the income from production of ore from mineral resources in Canada under clause 1204(1)(b)(ii)(A) of the Regulations, is also relevant to the computation of resource profits for purposes of the resource allowance deduction permitted under paragraph 20(1)(v.1) of the Act, it is clear that both subsection 65(1) and paragraph 2O(1)(v.1) rely on Part XII of the regulations for computation of resource profits. 4. ... " 24(1) A/Director Bilingual Services & Resource Industries Division Rulings Directorate ...

Should you wish our comments regarding the income taxation of taxpayers engaged in a resource industry, please feel free to get in touch with us. Yours truly, for Director Bilingual Services & Resource Industries Division Rulings Directorate Legislative and Intergovernmental Affairs Branch 000206 ...

2 August 1987 Income Tax Severed Letter 32445 F- Joint Venture Versus Partnership Unedited CRA Tags n/a LEGAL SERVICES- TAXATION         Resource Industries                                     Section Attn: C.T.A. ... Gauvreau       General Counsel             957-8955                                     3-2445 24(1) Subject: Joint Venture versus Partnership We are writing to advise you that the transactions contemplated by the legal opinion request which we previously submitted to you dated June 19, 1989, are no longer proposed transactions; consequently, we are withdrawing our request. We thank you for your assistance in this matter and would ask you to please return our files submitted with our request to Allan Nelson of the Resource Industries Section. ...

7 July 2010 Income Tax Severed Letter 2010-0371091R3- Supplementary to ruling 2008-029214 SUMMARY: Supplementary to ruling 2008-029214—none—Advance income tax ruling—Amendments to advance income tax rulingrelating to a time extension and foreign resource property. ... PRINCIPAL ISSUES: time extension to ruling # 2008-029214 [] on Foreign resource property XXXXXXXXXX 2010-037109 XXXXXXXXXX, 2010 Dear. ... Yours truly, Director Reorganizations and Resources Division Income Tax Rulings Directorate Legislation Policy Regulatory and Affairs Branch ...

SUBJECT: PURCHASERS OF HEAT SECTION: CLASS 34] Class 34 Secretariat, Energy, Mines & Resources Canada, 580 Booth St., 7th Floor, 921273 Ottawa K1A 0E4 E.Wheeler (613) 957-2100 Attention: D. Skinner June 9, 1992 Dear Sirs: Re: Class 34 & Purchasers of Heat This is further to our meeting of May 27, 1992 (Skinner, Titcomb, Guglich, Wheeler). ...

29 September 1989 Income Tax Severed Letter AC73788- Discount on Obligations and Foreign Exchange Losses on Repayment September 29, 1989 MONTREAL District OFFICE HEAD OFFICE Remi St-Louis Bilingual Services & Resource Audit Section Industries Division Section 148 M. ... If you have any question on this matter, please contact us. for the Director Bilingual Services and Resource Industries Division Rulings Directorate ...

26 June 1990 Income Tax Severed Letter ACC9575- Section 33- Subject List Unedited CRA Tags none DATE June 26, 1990 Control Unit Resource Industries Section Frank Gillman 957-9768 Attention: Caroline Desmarais-Lacroix FILE DOSSIER 7-901137 SUBJECT: OBJET: Section 33- Subject List We are writing in response to your memo of June 8, 1990 requesting that we provide you with a list of the main subjects the Resource Industries Section handle in addition to a list of the sections of the Act to which these subjects relate. ... Chief Resource Industries Section Bilingual Services and Resource Indudries Division Rulings Directorate WORK SECTION 33 I MINING AND OIL & GAS Alberta Royalty Tax Credit Canadian Exploration and Development Expenses 66(15)(b) Canadian Exploration Incentive Program CCEIP) Canadian Resource Property 66(15)(c) Canadian Exploration and Development Overhead Expense CCEDOE) Canadian Exploration Expense (CEE) 66.1(6) Canadian Development Expense (CDE) 66.2(5) Canadian Oil and Gas Property Expense (C0GPE) 66.4(5) Carved-out Income 66(14.6) & 209 Crown Royalties 12(l)(o),18(1) (m), 69(6) Cumulative Offset Account 66.5 Earned Depletion Base 65 Exploration and Development Shares 66.3 Farm-out 66(12.1) Flow-Through Shares 66(l5)(d.1) 66(12.6) to (12.75) Foreign Exploration and Development Expense 66(15) (e), 66(4) Foreign Resource Property 66(l5)(f) Frontier Exploration Allowance Gas or Oil Well Equipment Grubstakers 35(1) Industrial Mineral Mines Joint Exploration Corporation (JEC) 66(15)(g), 66(10) to (10.4) Mineral Resource 248(l) Minerals Mining Exploration Depletion Deduction (MEDA) Mining Taxes 20(l)(v) Oil or Gas well 248(1) Overburden Removal Pipelines Prescribed Shares Prime Metal Stage Principal Business Corporation (PBC) 66(15)(h) Production Royalties Prospectors 35(l) Reclamation Costs Resource Allowance 20(1)(v.l) Resource Royalties Successor Corporations 66.7 Supplementary Depletion Allowance II F0RESTRY Farm Woodlots Forestry Logging Logging Tax Deduction 127(l) & (2) Logs Lumber Pulp & Paper Saw Mills Timber Timber Limit Timber Resource Property 13(21)(d.1) Tree Farms Woodlots WORK SECTION 33 MINING, OIL & GAS AND FORESTRY ITA 12(1) (o)- royalties, etc. to be included in income l3(21)(d.l)- timber resource property 18(1)(1.1)- Petroleum and Gas Revenue Tax Act payments 18(1)(m)- royalties, etc. 20(l)(v)- mining taxes 20(1)(v.1)- resource allowance 20(1)(kk)- exploration and development grants 20(1) (11)- amount deemed to be tax payable 20(1(mm)- injection substances 20(15)- regulations 35- prospectors and grubstakers 59- consideration for foreign resource property, inter alia 59.1- involuntary disposition of resource property 65- allowance for oil or gas well, mine or timber limit 66- exploration and development expenses of PBC, inter alia 66.1- CEE 66.2- CDE 66.3- exploration and development shares 66.4- COGPE 66.5- cumulative offset account 66.6- application of 66.7(l), (2), etc. 66.7- successor rules 66.8- resource expenses of a limited partner 69(6) to 69(13)- phantom income 80.2- reimbursement of crown charges 127(1) & (2)- logging tax deduction 196- tax on deduction under section 66.5 208- tax on crown charges paid by a tax exempt person 209- tax on carved-out income Document Disclosed Pursuant to the Access to Information Act Document divulgué en vertu de la loi sur l'accès à l'information ...

8 November 1989 Income Tax Severed Letter ACC8489 F- Limited Partnership At-Risk Rules Unedited CRA Tags 96(2.2)96(2.2)(d)   89M12526   November 8, 1989 To: Review Committee Resource Industries Section   Allan B. Nelson   957-8984   Subject: Limited Parnter At-risk Rules Paragraph 96(2.2) of the Act Purpose We are writing to request your direction concerning the possible application of paragraph 96(2.2)(d) of the Act in a fact situation on which we have been asked to provide an advance income tax ruling. ... XXX Issue We have been asked to rule that the Indemnity given by the Resource Company to the Partnership will not reduce the limited partners' at-risk amounts pursuant to paragraph 96(2.2)(d) of the Act. ...