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TCC
Badoulary v. Human Resources, 2008 TCC 182
Human Resources, 2008 TCC 182 Docket: 2007-4087(OAS) BETWEEN: DJIVAPREMDJEE BADOURALY, Appellant, and THE MINISTER OF HUMAN RESOURCES AND SOCIAL DEVELOPMENT, Respondent. ... Translation certified true on this 9th day of May 2008. Brian McCordick, Translator Docket: 2007-4092(OAS) BETWEEN: DJARINA GOULAMALY, Appellant, and THE MINISTER OF HUMAN RESOURCES AND SOCIAL DEVELOPMENT, Respondent. ... THE MINISTER OF HUMAN RESOURCES AND SOCIAL DEVELOPMENT, DJARINA GOULAMALY v. ...
Technical Interpretation - Internal
19 October 1990 Internal T.I. 9026877 F - Deductible Crown Rentals and Resource Profits
19 October 1990 Internal T.I. 9026877 F- Deductible Crown Rentals and Resource Profits Unedited CRA Tags 1211(d), 1204 October 19, 1990 Audit Programs Directorate Resource Industries Special Audits Division Section E.H. ... Our understanding of the audit policy in your Oil and Gas Issue Report # O&G 02 is that Crown rentals which are deductible by virtue of Regulation 1211(d) should reduce resource profits computed under the provisions of Regulation 1204. ... Consequently, the second sentence in O&G 02 under Department's Policy should be replaced by "Since the potential source of income of non-producing properties would generally be from production, the deductible Crown rentals should reduce resource profits in the calculation of the resource allowance". 4. ...
TCC
Furma v. Human Resources, 2004 TCC 229
Human Resources, 2004 TCC 229 iN THE mATTER OF A REFERENCE UNDER SUBSECTION 28(2) OF THE OLD AGE SECURITY ACT, r.s.C. 1985 C. o – 9, AS AMENDED Docket: 2002-4497(OAS) BETWEEN: BALJINDER FURMA, Appellant, and THE MINISTER OF HUMAN RESOURCES DEVELOPMENT CANADA, Respondent.____________________________________________________________________ Reference heard on common evidence with the reference of Mukhtiar Furma (2002‑4498(OAS)) on December 15, 2003, at Toronto, Ontario, By: The Honourable Justice E.A. ... Bowie" Bowie J. iN THE mATTER OF A REFERENCE UNDER SUBSECTION 28(2) OF THE OLD AGE SECURITY ACT, r.s.C. 1985 C. o – 9, AS AMENDED Citation: 2004TCC229 Date: 20040319 Docket: 2002-4497(OAS) BETWEEN: BALJINDER FURMA, Appellant, and THE MINISTER OF HUMAN RESOURCES DEVELOPMENT CANADA, Respondent, Docket: 2002-4498(OAS) AND BETWEEN: MUKHTIAR FURMA, Appellant, and THE MINISTER OF HUMAN RESOURCES DEVELOPMENT CANADA, Respondent. ... Bowie" Bowie J. CITATION: 2004TCC229 COURT FILE NO.: 2002-4497(OAS) and 2002-4498(OAS) STYLE OF CAUSE: Baljinder Furma and Mukhtiar Furma and The Minister of Human Resources Development Canada PLACE OF HEARING: Toronto, Ontario DATE OF HEARING: December 15, 2003 REASONS FOR DECISION BY: The Honourable Justice E.A. ...
Technical Interpretation - External summary
6 February 2014 External T.I. 2013-0512191E5 - Mining Activities and SR & ED -- summary under Scientific Research & Experimental Development
6 February 2014 External T.I. 2013-0512191E5- Mining Activities and SR & ED-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development CEE excluded even if renounced An expenditure incurred by a resource corporation which qualifies as Canadian exploration expense cannot be a qualified expenditure in respect of SR&ED by virtue of para. ...
TCC
Abdul v. Human Resources, 2005 TCC 172
Human Resources, 2005 TCC 172 Docket: 2004-3210(OAS) BETWEEN: ABDUL RAHIM ABDUL-RAHMAN, Appellant, and THE MINISTER OF HUMAN RESOURCES AND DEVELOPMENT CANADA, Respondent.____________________________________________________________________ Appeal heard on February 14, 2005 at Montreal, Québec Before: The Honourable Justice Louise Lamarre Proulx Appearances: For the Appellant: The Appellant himself Counsel for the Respondent: Simon Petit ____________________________________________________________________ JUDGMENT The appeal from a decision of the Minister of Human Resources and Development Canada, further to a reference from a Review Tribunal pursuant to subsection 28(2) of the Old Age Security Act, is dismissed in accordance with the attached Reasons for Judgment. ... "Louise Lamarre Proulx" Lamarre Proulx, J. Citation: 2005TCC172 Date: 20050302 Docket: 2004-3210(OAS) BETWEEN: ABDUL RAHIM ABDUL-RAHMAN, Appellant, and THE MINISTER OF HUMAN RESOURCES AND DEVELOPMENT CANADA, Respondent. ... CITATION: 2005TCC172 COURT FILE NO.: 2004-3210(OAS) STYLE OF CAUSE: Abdul Rahim Abdul-Rahman and The Minister of Human Resources and Development Canada PLACE OF HEARING: Montreal, Québec DATE OF HEARING: February 14, 2005 REASONS FOR JUDGEMENT BY: The Hon. ...
News of Note post
31 March 2019- 11:17pm CRA states that a Canadian resource royalty interest requires a right to “take production” Email this Content Para. (d) of the definition of a Canadian resource property (CRP) includes: any right to a rental or royalty computed by reference to the amount or value of production from an oil or a gas well in Canada, or from a natural accumulation of petroleum, natural gas or a related hydrocarbon in Canada, if the payer of the rental or royalty has an interest in … the well or accumulation …. and 90% or more of the rental or royalty is payable out of, or from the proceeds of, the production from the well or accumulation. ... Summary of 7 June 2017 Canadian Petroleum Tax Society Roundtable, Q.2 under s. 66(15) – para. ...
The consideration incudes not only Oil Search shares or cash (subject to a U.S.$770M cap) but also “contingent value rights,” which will trade on the ASX and will entitle the holder to a cash payment based on the extent to which an interim resource assessment of a PNG natural gas project of InterOil shows a resource of greater than 6.2 trillion cubic feet equivalent ("tcfe"). For example, if the resource is measured at 10 tcfe, the CVRs would pay U.S.$1.17 billion in total. ... Summary of InterOil Booklet for its acquisition by Oil Search under Mergers & Acquisitions – Cross-Border Acquisitions – Inbound – Canadian Buyco. ...
FCA
Canada (Minister of Human Resources Development) v. Mahy, 2004 FCA 340
Canada (Minister of Human Resources Development) v. Mahy, 2004 FCA 340 Date: 20041012 Dockets: A-24-04 A-25-04 Citation: 2004 FCA 340 CORAM: RICHARD C.J. ... " FEDERAL COURT OF APPEAL NAMES OF COUNSEL AND SOLICITORS OF RECORD DOCKETS: A-24-04 STYLE OF CAUSE: MINISTER OF HUMAN RESOURCES DEVELOPMENT v. ... Morris Rosenberg, FOR THE APPLICANT Deputy Attorney General of Canada Ottawa, Ontario FEDERAL COURT OF APPEAL NAMES OF COUNSEL AND SOLICITORS OF RECORD DOCKETS: A-25-04 STYLE OF CAUSE: MINISTER OF HUMAN RESOURCES DEVELOPMENT v. ...
Administrative Letter
29 March 1990 Administrative Letter 74476 F - Resource Allowance and Class 29 CCA
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. ...
30 July 2014- 9:02am CRA confirms that negative ACB gains of non-residents from Canadian real estate or resource LP interests are exempt from tax Email this Content S. 40(3.1) deems the holder of an LP interest to realize a capital gain when the ACB calculation is otherwise about to go negative, but only goes on to deem there to be an associated disposition of property at that time for purposes of the capital gains deduction. CRA has confirmed that this means that a negative ACB gain of a non-resident from holding an LP interest which is taxable Canadian property is exempt from capital gains tax – but has drawn Finance’s attention to this anomaly. ... S. 40(3) deems the non-resident to realize a gain from a disposition of the shares – but only deems the non-resident to have disposed of the shares in the year for limited purposes not including s. 2(3)(c). ...