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29 March 1990 Administrative Letter 74476 F- Resource Allowance and Class 29 CCA Unedited CRA Tags 1204, 20(1)(v.1)   March 29, 1990 TO- EDMONTON DISTRICT OFFICE FROM- HEAD OFFICE Bob Kisinger Resource Industries Section Chief of Business and Basic Files G.R. ... Your questions and our responses thereto are as follows: (1)     Are the joint venture participants entitled to claim resource allowance? 24(1)      Accordingly, we advise that the joint venture participants do not have resource profits as defined in Regulation 1204 and as a result do not meet the requirements for the deduction described in paragraph 20(1)(v.1) of the Act and Regulation 1210.       ...

31 August 1992 Administrative Letter 9222076 F- Whether Partnership Interest Is CDN Resource Property Unedited CRA Tags 66(15) Canadian resource property, 66.1(4)(b)(ii), 66.7(3)(b)(i)   922207   John Chan   (613) 957-8975 August 31, 1992 Appeals and Referrals DivisionResource Industries SectionDon BeamishSection Chief Attention: D. ... In general terms, the first successor and second successor rules as they applied to taxation years ending before February 18, 1987 (the "old successor rules") provided for the computation of the first or second successor's deduction by reference to production from Canadian resource property in respect of which the successor had an interest; or had a right to take or remove petroleum or natural gas or a right to take or remove minerals from the Canadian resource property (hereafter referred to as the "right to take")-      see for example, subparagraphs 66.1(4)(b)(ii) and (5)(b)(ii) pertaining to the first and second successor's deduction, respectively, of successored Canadian exploration expense ("CEE"). ... Under the old successor rules, therefore, a first or second successor corporation was not permitted to claim a successor deduction with respect to income from Canadian resource properties owned by a partnership, simply because it was the partnership, not the successor corporation, that had an interest in the Canadian resource properties and the right to take. ...

1 June 1990 Administrative Letter 74836 F- Computation of Resource Profits Unedited CRA Tags 1204, 80(1), 13(7.4), 13(7.1), 12(1)(x) Special Audit Division Rulings Directorate E.H. Gauthier Resource Industries Director Section   John Chan   (613) 952-9019 S. Kapur Specialized Industries Section File No. 7-4836 SUBJECT: Request for Technical Interpretation 24(1) We are writing in reply to your request of March 22, 1990 for a technical interpretation of the income tax treatment  24(1) Your concern is primarily whether the assistance should be deducted from the expenses incurred in respect of  24(1) for purposes of computing 24(1) resource profits pursuant to section 1204 of the Income Tax Regulations (the "Regulations"). ...

4 October 1989 Administrative Letter F3216 F- Computation and Flow-through of Partnership of Losses and Resource Expenses by Limited Partners Unedited CRA Tags n/a   October 4, 1989 Mr. ... Burnett 957-2078   File No. F-3216 Interpretation Bulletin Project Number 1635 Computation and Flow-through of Partnership of Losses and Resources Expenses by Limited Partners Revision of IT-138R We have reviewed the above draft project and have no comments with respect to policy matters, current or pending, that are relevant to positions taken in the draft. We do, however, have the following comments: 1)     Page 1- Application- IT-183 was dated October 28, 1974, not October 22. 2)     Pages 7 and 8- Paragraph 25- The description of the amount deductible under section 101 is confusing.  ...

1997 Administrative Letter 971152B-: Tax Shelter- Prescribed Benefits & Revenue Guarantees Unedited CRA Tags: 237.1(1), ITR 231(6.1)(b)(ii), 143.2, 96(2.2)(d) Principal Issues: 1. ... Position: 1 & 2. Not as of the date of the ruling, based on certain provisos. 3 to 7. ... Yours truly for Director Resources, Partnerships and Trusts Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch XXXXXXXXXX ...

16 October 1989 Administrative Letter 58556 F- Meaning of "the Prime Metal Stage or its Equivalent" Unedited CRA Tags 1204(1) Director General Tax Policy Analysis Division File No. 5-8556 Energy, Mines & Resources Canada G.R. ... In the case at issue, 19(1) has framed its questions in the context of processing bauxite ore where there is a series of commercial products arising in the processing of such ore into aluminum ingots. 19(1) has asked the following questions on which we request your comments on: 1.       ... 3.      Does the answer to question 2 turn on whether a particular taxpayer processes and sells alumina as a primary product with say only a portion of the alumina processed further by him and sold as aluminum ingots, i.e. can the "prime metal stage" of a specific ore bauxite- change as between taxpayers or is it constant once industry usage as a whole is established? ...

6 July 1989 Administrative Letter 74076 F- Pipeline Right of Way and Easement Costs Unedited CRA Tags n/a   July 6, 1989 Mississauga District Office Head Office Appeals Division Resource Industries W 5est Section   Allan B. Nelson Ted Clarke (613) 957-8984   File No. 7-4076 Subject:  24(1) Pipeline Right of Way and Easement Costs Enclosed, as requested in your round trip memorandum dated June 26, 1989, is a copy of our July 4, 1986, reply to Audit's memo dated February 24, 1986, concerning pipeline right of way and easement costs. ...

The RDIA defines "facility" as the structures, machinery and equipment that constitute the necessary components of an M & P operation, other than an initial processing operation in a resource-based industry.  In our opinion, based on the definitions contained in the Regional Development Incentives Regulations, 1974, 24(1) would not be considered to be M & P and fits the definition of an initial processing operation in a resource based industry. c)     In our opinion, 24(1) does not constitute M & P for purposes of the M & P deduction.  ... One of the activities contained in those subparagraphs is the extraction of minerals from a mineral resource and in our opinion this would include 24(1). 2)     Transportation to the Processing Plant a)     As stated in paragraph 28 of IT-145R, activities related to the transportation of raw materials 24(1) to the plant do not qualify as M & P activities. ...

20 March 1990 Administrative Letter 90M03336 F- Ontario Income Tax Act- Foreign Tax Credit Unedited CRA Tags 7(1)(1), 120.1, 121, 122.3   March 20, 1990 Mrs. ... Nuckle Provincial and International Resource Officer Relations Division Enquiries E.E. Campbell Ottawa District Office   File No. 90M03336 Ontario Income Tax Act- Foreign Tax Credit In our conversation of March 8 we discussed the calculation of the provincial foreign tax credit on form T2036.  ...

13 January 1992 Administrative Letter 9133456 F- Bill C-18 Amendments- Successor Rules Unedited CRA Tags 66.7(12), 66.7(12.1), 66.7(4) Audit Technical Support Division Resource Industries K.R. Warren   Section Acting Director John Chan   (613) 957-8973 Attn:  Bharat Patel Industry Specialist Services Calgary D.O.                7-913345 Successor Rules- Subsections 66.7(12) and (12.1) This is in reply to your memorandum dated December 3, 1991 and the analysis attached thereto of a hypothetical situation involving the successor rules, namely, subsections 66.7(12) and (12.1) contained in Bill C-18 which received Royal Assent on December 17, 1991. ...