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Revenue Canada will treat widespread farmouts in which the farmee receives unproven resource property of the farmor as not giving rise to proceeds of disposition irrespective of whether or not the unproven resource property is contiguous to the property being explored or developed by the farmee. ... In summary, the favourable tax treatment would be extended in the following situations: (a) where the farmee explores and develops an unproven resource property of the farmor and the farmee receives an interest in that unproven resource property; (b) where the farmee explores and develops an unproven resource property of the farmor and the farmee receives an interest in another unproven resource property of the farmor. ... The question and answer was reviewed by John Kurrant, Oil & Gas Specialist on June 12 and he said that he does not have any concerns. ...

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 ...

10 October 1989 Income Tax Severed Letter AC57863- Termination of Flow-through Share Agreement Prior to Resource Company Incurring and Renouncing Promised Amounts 5-7863 19(1) 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 othervise 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. ... Yours truly, Section chief Resource Industries Section Bilingual Services and Resource Industries Division Rulings Directorate ...

27 June 2006 Internal T.I. 2006-0174191I7- Partnership Wind-Up and Resource Expenditures Unedited CRA Tags 98(3) 66(15) 66.1 Principal Issues: Taxation of partnership wind-up involving renounced resource expenditures. ... June 27, 2006 Vancouver Tax Service Office HEADQUARTERS John Lund Allan Nelson Complex Business Enquiries (613) 443-7253 2006-017419 Winding Up of Limited Partnership and Resource Expenditures Technical Interpretation We are writing in response to your March 1, 2006, facsimile transmission, which asked for our comments regarding the appropriate income tax treatment in a situation involving a limited partnership wind-up and the allocation of resource expenses to the former partners. ... We modified the hypothetical facts slightly to highlight what appear to be the two key aspects of your questions: the partnership wind-up and the flow through of the renounced resource expenses. ...

Robert Parsons stated: “ if the producer should choose to close out the forward sales contract earlier than it was required to do, by purchasing an equivalent amount of product, this action does not alter the characterization of the gain or loss on the forward sales contract as a hedging transaction. ... Timing of inclusion in gross resource Drofits- Regulation 1204 The positions described in #9226381 (October 2, 1992), in particular the discussion about resource profit recognition, have not changed. ... John Chan, Manager Resource Industries Section Resources, Partnerships and Trusts Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ...

20 January 2010 Internal T.I. 2009-0348571I7- Interest Rate Swaps and Resource Profits Principal Issues: Whether amounts paid by the taxpayer under various interest rate swap agreements need to be deducted in computing the taxpayer's resource profits Position: Yes Reasons: The payments were made in the course of carrying on its resource business and are not related to a source of income that does not include a resource activity January 20, 2010 XXXXXXXXXX Resources Industry Section Large File Case Manager T. ... The Queen 99 DTC 5669 [SCC] and Stewart v The Queen 2002 DTC 6969 "XXXXXXXXXX " However, we have been unable to identify any comments in either of these decisions that support the Representative's position. ... Resource Profits Subsection 1204(1.1) of the Regulations reads, in part, as follows:.... ...

In this case refund interest should not be included in gross resource profits. ... Legislation Adjusted resource profits is computed by reference to the definitions of "resource profits" and "gross resource profits" in subsections 1204(1.1) and 1204(1) of the Regulations, respectively. ... It is arguable that interest income on short term deposits, as well as interest on overpayment of taxes, would not be included in the narrower term 'income from the production and processing in Canada...of ore... ' used in paragraph 1204(1)(b)(ii) of the Regulations. ...

19 June 1990 Internal T.I. 74779 F- Non-capital Losses & RRSP Contributions Unedited CRA Tags 3(a), 3(c), 146(1) earned income, 146(5)   June 19, 1990 THUNDER BAY DISTRICT OFFICE HEAD OFFICE Appeals Division Resource Industries   Section   Frank S. ... Christy (613) 957-9768 19(1) File No. 7-4779 SUBJECT:  Renounced Resource Expenses creating Non-Capital Losses & RRSP Contributions Resource Expense Deduction This is in response to your memorandum dated February 26, 1990, concerning the above-mentioned topics. ... ChiefResource Industries SectionBilingual Service and Resource Industries DivisionRulings Directorate  ...

4 December 1989 Ministerial Letter 73828A F- Integrated Sawmill & Pulpmill Subsection 125.1(1)- M & P Deduction Unedited CRA Tags 125.1(1), 5202   December 4, 1989 E.H. Gauthier Resource Industries Section Director Frank Gillman Special Audits Division 957-9768 Attention:  Merv Scott (Penticton) 7-3828 Forestry Specialist SUBJECT:  Integrated Sawmill & Pulpmill Subsection 125.1(1)- M & P Deduction We are writing in response to your memo dated April 13, 1989, wherein you requested that we reconsider a previous opinion rendered by the Rulings Directorate dated December 1, 1986 as to whether the transportation of woodchips from a sawmill (whether owned by a taxpayer or otherwise) to a pulpmill is a "qualified activity" as defined at paragraph 5202 of the Income Tax Regulations. ... Conclusion 24(1) DirectorBilingual Services & ResourceIndustries DivisionRulings Directorate ...

19 June 1990 Income Tax Severed Letter AC74779- Non-capital Losses & RRSP Contributions Unedited CRA Tags 146(1), 146(5) JUNE 19 1990 THUNDER BAY DISTRICT OFFICE HEAD OFFICE Appeals Division Resource Industries Section Frank S. ... Christy 19(1) 7-4779 Renounced Resource Expenses creating Non-Capital Losses & RRSP Contributions Resource Expense Deduction This is in response to your memorandum dated February 26, 1990, concerning the above-mentioned topics. ... Chief Resource Industries Section Bilingual Service and Resource Industries Division Rulings Directorate Document Disclosed Pursuant to the Access to Information Act Document Divulgué en vertu de la loi sur l'accès à l'information ...