Search - ”资源化利用" resource

Social Security Agreement ReSource Deductions Unedited CRA Tags n/a 19(1) Al Watson   (613) 957-2072   HBW 4131-U3 February 14, 1990 19(1) We are writing further to your letter of July 25, 1989, which was received on referral from our Source Deductions Division concerning an extension of coverage under the Agreement of Social Security between Canada and the United States of America (the "Agreement").  ... SavageA/DirectorProvincial and International Relations Division c.c.:     Pauline TourangeauSource Deductions Division ...

23 November 1989 Ruling 58941 F- "Cost Amount" of Canadian Resource Property Unedited CRA Tags 248(1) cost amount 19(1) File No. 5-8941   J. Chan   (613) 952-9019 November 23, 1989 Dear Sirs: Re:  Request for Technical Interpretation "Cost Amount" of Canadian Resource Property We are writing in reply to your letter dated October 18, 1989, wherein you requested our interpretation of the meaning of "cost amount" of Canadian resource property for purposes of the Income Tax Act (the "Act"). As you indicate, the relevant provision of the Act to determining the cost amount of Canadian resource property is paragraph (f) of the definition of "cost amount" in subsection 248(1) which states that "cost amount" to a taxpayer of a property at any time means.       ...

10 October 1989 Ruling 57863 F- Termination of Flow-through Share Agreement Prior to Resource Company Incurring and Renouncing Promised Amounts Unedited CRA Tags 66(12.73), 66(15) flow-through share ITR 6202.1 19(1) File No. 5-7863   J. ... 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, ($) to issue shares pursuant to the agreement, or (3) to flow-through any incentive payments to which the resource company would otherwise be entitled. ... (i)     to provide assistance, (ii)       to make a loan or payment, (iii)       to transfer property, or (iv)       otherwise to confer a benefit by any means whatever, including the payment of a dividend, either immediately or in the future, that may reasonably be considered to be, directly or indirectly, a repayment or return by the corporation... of all or part of the consideration for which the share was issued... ...

14 September 1989 Ruling 58421 F- Renunciation of Resource Expenditures Incurred Prior to the Date of an Agreement in Writing Unedited CRA Tags 66(12.6), 66(12.62), 66(12.64), 66(15) flow-through share 19(1) File No. 5-8421   Frank S. Gillman   (613) 957-8953 September 14, 1989 Dear Sirs: Re:  Agreement in writing Paragraph 66(15)(d.1) of the Income Tax Act (the "Act") This is in reply to your letter dated July 19, 1989, in which you requested our opinion regarding our interpretation of paragraph 66(l5)(d.1) of the Act as it relates 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. ... The aforesaid subsections may be paraphrased as follows in stating the requirement as to when a principal-business corporation has to incur the various expenses so that they qualify for "flow through" purposes:      "... and, during the period commencing on the day the agreement was entered into and ending 24 months after the end of the month that included that day, the corporation has incurred (the specific expense), the corporation may..., renounce,..., by which those expenses incurred by it during that period... ...

2009 Ruling 2008-0292141R3- ruling- foreign resource property Unedited CRA Tags 66(16) Principal Issues: 1.Will the Net Smelter return taken back on sale of shares constitute a foreign resource property? ... The other shareholders in XXXXXXXXXX are XXXXXXXXXX, which holds XXXXXXXXXX % of the shares of XXXXXXXXXX, which holds the remaining XXXXXXXXXX %, both directly and via XXXXXXXXXX. 5. ... The Corporation has maintained its current ownership of XXXXXXXXXX % (directly and indirectly) since XXXXXXXXXX. 7. ...

In this letter, the following terms have the meanings specified: (a) "Act" means the Income Tax Act, R.S.C 1985 (5th Supp.) c.1, as amended to the date hereof, and, unless otherwise stated, every reference herein to a Part, section, subsection, paragraph or subparagraph is a reference to the relevant provision of the Act; (b) "Canadian resource property" has the meaning assigned by subsection 66(15); (c) "CCOGPE" means "cumulative Canadian oil and gas property expense" within the meaning assigned by subsection 66.4(5); (d) "COGPE" means "Canadian oil and gas property expense" within the meaning assigned by subsection 66.4(5); (e) "GOR agreement " means the agreement described in paragraphs 5, 6 and 7 below between Petroleum Co. and the resource company, and which will be substantially similar to the Royalty Agreement dated XXXXXXXXXX that was provided with your advance income tax ruling request; (f) "Grantor of the GOR agreement" is the resource company that is party to the GOR agreement with Petroleum Co.; and (g) "Petroleum Co. ... Petroleum Co. does not have the resources to develop certain properties it has discovered and as such, GOR agreements will be entered into with resource companies who are able to develop the properties ("the Grantors of GOR agreements"). 7. ... Yours truly, for Director Resources, Partnerships and Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch ...

2005 Ruling 2005-0149001R3 F- Underground Exploration Program- New Mine & CEE Unedited CRA Tags 66.1(6) 66.2(5) 248(1) "Mineral Resource" Principal Issues: A) Whether expenses relating to an underground exploration program to be carried out will be related to a mine that has come into production in reasonable commercial quantities, or to a potential or actual extension thereof. ... Dans sa totalité, le Projet Souterrain nécessitera des investissements estimés à XXXXXXXXXX $. ... Les coûts estimés pour la seconde phase de forage sont évalués à XXXXXXXXXX $ totalisant XXXXXXXXXX mètres en forage XXXXXXXXXX. 9. ...

2006 Ruling 2006-0206021R3 F- Underground Exploration Program- New Mine & CEE Unedited CRA Tags 66.1(6) 66.2(5) 248(1) "Mineral Resource" Principal Issues: A) Whether expenses relating to an underground exploration program to be carried out will be related to a mine that has come into production in reasonable commercial quantities, or to a potential or actual extension thereof. ... Dans sa totalité, le Projet Souterrain nécessitera des investissements estimés à XXXXXXXXXX $. ... L'ensemble des travaux de forage sous terre totalisera XXXXXXXXXX mètres en forage pour un coût total maintenant estimé à XXXXXXXXXX $. 8. ...

2000 Ruling 1999-0012763- Class 43-1 System & Heat Rate Requirements Unedited CRA Tags class 43-1 1104(14) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Reasons: (a) Based upon the opinion of Natural Resources Canada dated XXXXXXXXXX, Plant XXXXXXXXXX for the purpose of subparagraph (c)(i) of Class 43.1 in Schedule II of the Regulations. ... Yours truly, for Director Resources, Partnerships and Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch ...

The common shares of the Corporation are listed on the XXXXXXXXXX under the ticker symbol "XXXXXXXXXX " and are widely held by the public. 4. The business of the Corporation consists solely of the exploration for mineral resources. ... Yours truly, for Director Reorganizations and Resources Division Income Tax Rulings Directorate Legislation Policy Regulatory and Affairs Branch ...