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Educators – Tax Resources and Financial Literacy

Educators – Tax Resources and Financial Literacy RC4488 Rev.16. Educator-led programs The Canada Revenue Agency (CRA) offers two free educator-led products that are easy to teach and understand. ...

1 September 1992 Income Tax Severed Letter 9225591 - Finished Goods in the Resource Industries ITC/M & P

1 September 1992 Income Tax Severed Letter 9225591- Finished Goods in the Resource Industries ITC/M & P Unedited CRA Tags 127(11)(b)(i), 125.1(3)(b), Reg. 5202 REVENUE CANADA FORESTRY TAX CONFERENCE PRESENTATION BY RULINGS "FINISHED GOODS" FOR ITC AND M&P PURPOSES After a detailed study conducted during 1991, supported by a written opinion from the Department of Justice ("Justice"), Rulings adopted the view that the products of the extractive industries, such as the logs (the felled trees) from logging, would not constitute "finished goods" referred to in subparagraph 127(11)(b)(i) of the Income Tax Act and paragraph (d) of the definition of "qualified activities" in section 5202 of the Income Tax Regulations for purposes of determining a taxpayer's investment tax credits ("ITC") and manufacturing and processing ("M&P") profits. ... Prepared by:John Chan Date: September 1, 1992 File #: 7-922559 Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information ...

Randy S. Morphy, Kim Maguire, "An Update on the Taxation of Farm-outs", Resource Sector Taxation, Vol. IX, No. 3, 2013, p. 661. -- summary under Canadian Resource Property

Morphy, Kim Maguire, "An Update on the Taxation of Farm-outs", Resource Sector Taxation, Vol. ... Canadian Pipelines & Petroleum Limiter et al. [fn 11: (2959), 21 DLR (2d) 497 (S.C.C.) at 169-70, although we note that in the particular case, the Court found that the option was rendered void and of no effect because of a regulatory prohibition. ... If the resource property subject to the option qualifies as a Canadian resource property (and presumably it would), [fn 12: A mineral property would qualify under paragraph (b) (any right, licence or privilege to prospect, explore drill or mine for minerals) in the case of a working interest and under paragraph (g) (any real property the principal value of which depends on mineral resource content) in the case of a fee simple interest. ...

NOTICE269 - For discussion purposes only – Draft GST/HST Memorandum 3.7, Natural Resources

NOTICE269 For discussion purposes only – Draft GST/HST Memorandum 3.7, Natural Resources Notice to the reader Reference in this publication is made to supplies that are subject to the GST or the HST. ...

16 August 2000 External T.I. 2000-0031305 - Gross Resource Profits & Gas/Oil well equi,

16 August 2000 External T.I. 2000-0031305- Gross Resource Profits & Gas/Oil well equi, Unedited CRA Tags 1104(2) 1204(1)(b) 1204(3) 248(1) 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. ... Pursuant to paragraph 1204(1)(b) of the Regulations, "gross resource profits" of a taxpayer include the amount, if any, of the aggregate of his incomes from (i) the production of petroleum, natural gas, related hydrocarbons or sulphur from (A) oil or gas wells in Canada operated by the taxpayer, or (B) natural accumulations (other than mineral resources) of petroleum or natural gas in Canada operated by the taxpayer... ... Yours truly, John Chan, CA Manager Resource Industries Section Resources, Partnerships and Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch?? ...

Section 3 – Spending and human resources

Section 3 – Spending and human resources Document navigation Previous- Section 2 – Planned results Next- Planned spending CRA spending trend (dollars) 2015-16 2016-17 2017-18 2018-19 2019-20 2020-21 Actuals Forecast Spending Planned Spending Statutory 1,034,149,642 936,635,156 942,479,230 916,610,222 913,826,933 911,597,459 Voted 3,112,837,652 3,453,312,607 3,877,966,949 3,288,115,538 3,304,601,598 3,265,420,851 Total 4,146,987,294 4,389,947,763 4,820,446,179 4,204,725,760 4,218,428,531 4,177,018,310 In fiscal year 2018-19, Planned Spending is identical to expenditure levels presented in the Main Estimates. ... Planned human resources Human resources planning summary for Core Responsibilities and Internal Services (full-time equivalents) Core responsibilities and internal services Footnote 1 2015-16 Actual 2016-17 Actual 2017-18 Forecast 2018-19 Planned 2019-20 Planned 2020-21 Planned Tax 28,981 29,529 30,737 30,691 30,882 30,357 Benefits 1,287 1,299 1,558 1,506 1,474 1,463 Taxpayers' Ombudsman Footnote 2 21 25 31 31 31 31 Subtotal 30,289 30,853 32,326 32,228 32,387 31,851 Internal services 7,688 7,875 8,214 7,707 7,606 7,369 Total Canada Revenue Agency 37,977 38,728 40,540 39,935 39,993 39,220 The increase in forecasted FTEs in 2017-18 is largely attributable to new funding received to implement and administer measures announced in the 2017 Federal Budget as well as growth in funding for measures announced in the 2016 Federal Budget. ... Return to footnote2 referrer Document navigation Previous- Section 2 – Planned results Next- Page details Date modified: 2018-04-16 ...

CRA finds that an Alberta coniferous tree-harvesting right was a timber resource property

13 March 2018- 1:28am CRA finds that an Alberta coniferous tree-harvesting right was a timber resource property Email this Content Rather than reviewing the quite complex jurisprudence on what is a timber resource property, CRA looked at a timber removal right that was effectively a renewal of some timber removal rights that had been granted by the Alberta government in 1967 and 2004, and simply stated: Based on jurisprudence … and the facts and assumptions described above, the New Quota (whether it is viewed as a single property or a combination of two properties) would qualify as a timber resource property pursuant to the definition of that term in subsection 13(21). ... Summary of 6 February 2018 External T.I. 2017-0732151E5 under s. 13(21) – timber resource property. ...

Folio reference to Mark Resources fails to acknowledge its obsolescence

30 July 2015- 1:35am Folio reference to Mark Resources fails to acknowledge its obsolescence Email this Content In Folio S3-F6-C1, CRA indicates (perhaps somewhat contrary to TDL and Swirsky) that it is only in quite limited circumstances that it will consider investments in common shares to not be an eligible use of borrowed money. However, it then notes that in Mark Resources, where borrowed money was used to fund a cross-border investment in a U.S. ... " Leaving aside that the scheme would no longer work anyway, " Mark Resources is a clear outlier" as it departs from the s. 20(1)(c) (largely direct) use test as subsequently clarified by the Supreme Court of Canada (e.g., in Singleton). ...

NOTICE269 For discussion purposes only – Draft GST/HST Memorandum 3.7, Natural Resources

13 August 1992 External T.I. 9207735 F - Resource Royalty Payments - Resource Profits

13 August 1992 External T.I. 9207735 F- Resource Royalty Payments- Resource Profits Unedited CRA Tags 66(15) Canadian resource property, ITR 1206(9), ITR 1210(1)(a)(i)(a), ITR 1204(1)(b), ITR 1204(1)(b.1) 24(1) 920773 John Chan (613) 957-8975 Attention: 19(1) Dear Sirs: Re: Resource Royalty Payments This is in reply to your letter dated March 12, 1992 wherein you requested a technical interpretation in connection with the application of certain provisions of the Income Tax Act (the "Act") and the Income Tax Regulations (the "Regulations") to resource royalty payments in the context of a hypothetical fact situation. ... the production revenue from the CRP would be included in the computation of Corporation A's income for purposes of the Act and in the calculation of Corporation A's resource profits under paragraph 1204(1)(b) of the Regulations; 2. ... the GOR paid by Corporation A would not reduce Corporation A's resource profits in computing its resource allowance under clause 1210(1)(a)(i)(A) of the Regulations; and 4. ...

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