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Resource Capital Fund – Australian decision suggests that many or most Canadian mining company shares may not be taxable Canadian property

4 May 2013- 9:26pm Resource Capital Fund – Australian decision suggests that many or most Canadian mining company shares may not be taxable Canadian property Email this Content The Australian Federal Court found that even if a sale of shares of an Australian gold mining company had not been Treaty-exempt (as discussed in the post below), the company should not be considered to have more than 50% of its assets as Australian real property (i.e., its mining rights), so that the gain also would not have been taxable under the Australian equivalent of the taxable Canadian property rules. ... Summary of Resource Capital Fund III LP v. Commissioner of Taxation, [2013] FCA 363 (Fed. Ct. of Austr.) under Treaties – Art. 13. ...

16 May 1983 Income Tax Severed Letter 7-2462 - [Part XII of the Income Tax Regulations ("ITR") — Royalty Trusts — Reporting of resource income and allowances]

16 May 1983 Income Tax Severed Letter 7-2462- [Part XII of the Income Tax Regulations ("ITR") — Royalty Trusts — Reporting of resource income and allowances] DATE: May 16, 1983 TO- COMPLIANCE DIRECTORATE Audit Programs Division FROM- CORPORATE RULINGS DIRECTORATE J.C. ... McDonald Estate and Trust Group RE: Part XII of the Income Tax Regulations ("ITR") Royalty Trusts Reporting of resource income and allowances A correction is required to our memorandum of April 29, 1983, a copy of which is attached. ... Chief Mines, Oil & Forest Industries Section Specialty Corporations Rulings Division Corporate Rulings Directorate Legislation Branch Attachment ...

Imperial Oil Resources Limited v. Canada (Attorney General), 2008 DTC 6657, 2008 FC 1037 -- summary under Payment & Receipt

Imperial Oil Resources Limited v. Canada (Attorney General), 2008 DTC 6657, 2008 FC 1037-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt embedded royalty reduction was not an amount received The Alberta government granted a reduction in the royalties the taxpayer otherwise would have been required to pay to Alberta on condition that the taxpayer invest in an expansion of the Syncrude project. ...

St. Ives Resources Ltd. v. MNR, 90 DTC 1375, [1990] 1 CTC 2539 (TCC), aff'd 92 DTC 6223 (FCTD), briefly aff'd in turn at 94 DTC 6261 (FCA) -- summary under Rectification & Rescission

Ives Resources Ltd. v. MNR, 90 DTC 1375, [1990] 1 CTC 2539 (TCC), aff'd 92 DTC 6223 (FCTD), briefly aff'd in turn at 94 DTC 6261 (FCA)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission must give effect to agreement In refusing to recognize a price rectification agreement, Sarchuk, J. stated (p. 1378): "Rectification is an 'equitable remedy' whereby one party to a contract seeks the court's intervention to rectify a written instrument which does not accurately reflect the terms agreed to orally by the parties prior to putting their agreement down in writing... the remedy of rectification is not available to correct a mistaken assumption of fact. ...

Resource Capital Fund IV LP – Full Federal Court of Australia finds that the effecting of a share sale pursuant to an Australian Scheme of Arrangement pointed to an Australian source

21 April 2019- 11:41pm Resource Capital Fund IV LP – Full Federal Court of Australia finds that the effecting of a share sale pursuant to an Australian Scheme of Arrangement pointed to an Australian source Email this Content Two Caymans investment LPs with mostly U.S. ... That arrangement took place in Australia, and accordingly, because the scheme was the “proximate” origin of the profits earned, and because of the other connections with Australia summarised by the primary judge … including the location of the mine in Western Australia, those profits had a source in Australia. ... Summaries of Commissioner of Taxation v Resource Capital Fund IV LP [2019] FCAFC 51 under s. 152(1), s. 115(1)(a)((ii) and s. 248(1) – taxable Canadian property – para. ...

Barejo – Federal Court of Appeal states that determining whether the notes in Barejo were debt for purposes of the ITA rather than s. 94.1 would be “an improper use of judicial resources”

1 December 2016- 12:09am Barejo – Federal Court of Appeal states that determining whether the notes in Barejo were debt for purposes of the ITA rather than s. 94.1 would be “an improper use of judicial resources” Email this Content The Federal Court of Appeal has dismissed the Barejo appeal – but on the grounds that the Rule 58 question posed to the Tax Court was whether the “notes” in question were debts for purposes of the Act rather than for purposes of s. 94.1 thereof. ... “that endeavouring to dispose [of] the appeals on the merits would serve no useful purpose and give rise to an improper use of judicial resources.” ...

RCF IV – Federal Court of Australia finds that gains of U.S. limited partners from sales of an Australian resource company were not Treaty exempt but were not TCP-type gains

19 February 2018- 9:19pm RCF IV – Federal Court of Australia finds that gains of U.S. limited partners from sales of an Australian resource company were not Treaty exempt but were not TCP-type gains Email this Content Two Caymans investment LPs (“RCF IV” and RCF V”) whose limited partners were mostly U.S. residents, realized gains from the disposal of shares of significant shareholdings in a TSX-listed Australian corporation (Talison Lithium) which, through a grandchild corporation, held mining leases in Australia and carried out an operation there of mining lithium ores and processing them. ... Summaries of Resource Capital Fund IV LP v Commissioner of Taxation [2018] FCA 41 under Treaties – Income Tax Conventions – Art. 3, Art. 13, s. 248(1) – taxable Canadian property – (d), s. 115(1)(a)(ii), s. 9 – capital gain. v. profit – shares, General Concepts – stare decisis, s. 152(1). ...

Alta Energy – Supreme Court of Canada finds that Treaty shopping to avoid capital gains tax on Canadian resource assets was contemplated, and not a Treaty abuse

28 November 2021- 11:20pm Alta Energy – Supreme Court of Canada finds that Treaty shopping to avoid capital gains tax on Canadian resource assets was contemplated, and not a Treaty abuse Email this Content Two US firms transferred their investment in a Canadian subsidiary (Alta Canada), that was to develop a shale formation in northern B.C., to a Luxembourg s.à r.l. ... Canada “could also have insisted on a subject-to-tax provision” under which it would forego its right to tax capital gains only if the other state actually taxed those gains – but did not. ... Alta Energy Luxembourg S.A.R.L., 2021 SCC 49 under s. 245(4), Treaties – Income Tax Conventions, Art. 4, Statutory Interpretation- Treaties. ...

28 November 1989 External T.I. 58940 F - Diamond Deposits — Mineral Resource

28 November 1989 External T.I. 58940 F- Diamond Deposits — Mineral Resource Unedited CRA Tags 248(1) mineral resource 19(1) File No. 5-8940 G.R. White (613) 957-8585 November 28, 1989 Dear Sirs: Re: Diamond Deposits- Mineral Resource We are writing in reply to your letter dated October 19, 1989, in which you requested certification that any diamond deposits discovered in kimberlite pipes as a result of the 24(1) would qualify as a mineral resource as defined in subsection 248(1) of the Income Tax Act (the "Act"). ... Yours truly, Section Chief Resource Industries SectionBilingual Services and Resource Industries DivisionRulings Directorate ...

HR – Human Resources Group – Annual rates of pay

HR – Human Resources Group – Annual rates of pay On this page Rates of pay tables for levels HR-01 to HR-07 HR Group pay notes Appendix A – Implementation of retroactive and prospective changes to compensation One-Time Allowance Related to the Performance of Regular Duties and responsibilities Implementation Rates of pay for levels HR-01 to HR-07 HR-01 – Annual rates of pay (in dollars) Effective Dates Salary range October 1, 2021 39,677 to 58,789 October 1, 2022 – 1.25% wage adjustment 40,173 to 59,524 October 1, 2022 – 3.5% 41,580 to 61,608 October 1, 2023 – 0.5% pay line adjustment 41,788 to 61,917 October 1, 2023 – 3% 43,042 to 63,775 October 1, 2024 – 0.25% wage adjustment 43,150 to 63,935 October 1, 2024 – 2% 44,013 to 65,214 October 1, 2025 – 2% 44,894 to 66,519 HR-02 – Annual rates of pay (in dollars) Effective dates Step 1 Step 2 Step 3 Step 4 Step 5 Step 6 Step 7 October 1, 2021 56,748 59,229 61,858 64,619 67,531 70,595 73,133 October 1, 2022 – 1.25% wage adjustment 57,458 59,970 62,632 65,427 68,376 71,478 74,048 October 1, 2022 – 3.5% 59,470 62,069 64,825 67,717 70,770 73,980 76,640 October 1, 2023 – 0.5% pay line adjustment 59,768 62,380 65,150 68,056 71,124 74,350 77,024 October 1, 2023 – 3% 61,562 64,252 67,105 70,098 73,258 76,581 79,335 October 1, 2024 – 0.25% wage adjustment 61,716 64,413 67,273 70,274 73,442 76,773 79,534 October 1, 2024 – 2% 62,951 65,702 68,619 71,680 74,911 78,309 81,125 October 1, 2025 – 2% 64,211 67,017 69,992 73,114 76,410 79,876 82,748 HR-03 – Annual rates of pay (in dollars) Effective dates Step 1 Step 2 Step 3 Step 4 Step 5 October 1, 2021 71,583 74,106 76,727 79,454 82,312 October 1, 2022 – 1.25% wage adjustment 72,478 75,033 77,687 80,448 83,341 October 1, 2022 – 3.5% 75,015 77,660 80,407 83,264 86,258 October 1, 2023 – 0.5% pay line adjustment 75,391 78,049 80,810 83,681 86,690 October 1, 2023 – 3% 77,653 80,391 83,235 86,192 89,291 October 1, 2024 – 0.25% wage adjustment 77,848 80,592 83,444 86,408 89,515 October 1, 2024 – 2% 79,405 82,204 85,113 88,137 91,306 October 1, 2025 – 2% 80,994 83,849 86,816 89,900 93,133 HR-04 – Annual rates of pay (in dollars) Effective dates Step 1 Step 2 Step 3 Step 4 Step 5 October 1, 2021 80,270 83,138 86,122 89,223 92,439 October 1, 2022 – 1.25% wage adjustment 81,274 84,178 87,199 90,339 93,595 October 1, 2022 – 3.5% 84,119 87,125 90,251 93,501 96,871 October 1, 2023 – 0.5% pay line adjustment 84,540 87,561 90,703 93,969 97,356 October 1, 2023 – 3% 87,077 90,188 93,425 96,789 100,277 October 1, 2024 – 0.25% wage adjustment 87,295 90,414 93,659 97,031 100,528 October 1, 2024 – 2% 89,041 92,223 95,533 98,972 102,539 October 1, 2025 – 2% 90,822 94,068 97,444 100,952 104,590 HR-05 – Annual rates of pay (in dollars) Effective dates Step 1 Step 2 Step 3 Step 4 Step 5 October 1, 2021 89,244 92,361 95,713 99,198 102,769 October 1, 2022 – 1.25% wage adjustment 90,360 93,516 96,910 100,438 104,054 October 1, 2022 – 3.5% 93,523 96,790 100,302 103,954 107,696 October 1, 2023 – 0.5% pay line adjustment 93,991 97,274 100,804 104,474 108,235 October 1, 2023 – 3% 96,811 100,193 103,829 107,609 111,483 October 1, 2024 – 0.25% wage adjustment 97,054 100,444 104,089 107,879 111,762 October 1, 2024 – 2% 98,996 102,453 106,171 110,037 113,998 October 1, 2025 – 2% 100,976 104,503 108,295 112,238 116,278 HR-06 – Annual rates of pay (in dollars) Effective dates Step 1 Step 2 Step 3 Step 4 Step 5 October 1, 2021 99,931 103,585 107,384 111,345 115,349 October 1, 2022 – 1.25% wage adjustment 101,181 104,880 108,727 112,737 116,791 October 1, 2022 – 3.5% 104,723 108,551 112,533 116,683 120,879 October 1, 2023 – 0.5% pay line adjustment 105,247 109,094 113,096 117,267 121,484 October 1, 2023 – 3% 108,405 112,367 116,489 120,786 125,129 October 1, 2024 – 0.25% wage adjustment 108,677 112,648 116,781 121,088 125,442 October 1, 2024 – 2% 110,851 114,901 119,117 123,510 127,951 October 1, 2025 – 2% 113,069 117,200 121,500 125,981 130,511 HR-07 – Annual rates of pay (in dollars) Effective dates Salary range October 1, 2021 105,970 to 127,947 October 1, 2022 – 1.25% wage adjustment 107,295 to 129,547 October 1, 2022 – 3.5% 111,051 to 134,082 October 1, 2023 – 0.5% pay line adjustment 111,607 to 134,753 October 1, 2023 – 3% 114,956 to 138,796 October 1, 2024 – 0.25% wage adjustment 115,244 to 139,143 October 1, 2024 – 2% 117,549 to 141,926 October 1, 2025 – 2% 119,900 to 144,765 Rates of pay will be adjusted within one hundred and eighty (180) days from the date of approval. ... HR Group pay notes The non-salary terms and conditions of employment of employees who are incumbents of positions classified in the HR Group, including indeterminate, determinate and part-time employees, are set out in the Directive on Terms and Conditions of Employment for the Human Resources Group and other relevant policy instruments. ... Implementation The purpose of this appendix is to give effect to a modified approach to the calculation and administration of retroactive payments corresponding to revised Human Resources (HR) Group rates of pay approved by the Commissioner on September 22, 2023. ...

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