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1 June 1990 Internal T.I. 74847 F- Oil & Gas Steering Committee Unedited CRA Tags n/a   June 1, 1990 Special Audits Division Resource Industries E.H. ... Gauvreau   957-8953   File No. 7-4847 Subject: Oil & Gas Steering Committee Meeting Minutes We are writing in reply to your request of March 28, 1990 to determine whether the above-captioned minutes contain errors or omissions. ...

The term Canadian resource property ("CRP") is defined in subsection 66(15) of the Act. ... A carries on an oil & gas business in Canada. In the transaction with the Canadian oil & gas company, Mr. ... A's CCOGPE pool had an opening balance of $25,000, the CCOGPE pool would be in a credit balance of $75,000, computed as follows: Opening Balance + Rights to Royalties – Proceeds of Disposition = Closing Balance $25,000 + $300,000- $100,000- $300,000 = ($75,000). ...

7 June 1990 Income Tax Severed Letter AC74847- Oil & Gas Steering Committee Unedited CRA Tags none Special Audits Division Resource Industries E.H. ... Gauvreau 957-8953 7- 4847 Oil & Gas Steering Committee Meeting Minutes We are writing in reply to your request of March 28, 1990 to determine whether the above-captioned minutes contain errors or omissions. ... Director Bilingual Services and Resource Industries Division Rulings Directorate Document Disclosed Pursuant to the Access to Information ActDocument Divulgué en vertu de la loi sur l'accès à l'information ...

13 October 2004 Internal T.I. 2004-0060441I7- Hedging Gains / Losses of Partnership Unedited CRA Tags 20(1)(v.1) Reg 1206(3) Reg 1210(3) Principal Issues: Whether gains / losses realized by a partnership from a hedging activity may qualify for inclusion in the determination of the adjusted resource profits of a member of the partnership. Position: Yes, provided the hedging relates to qualifying production of the partnership such that the gains / losses would be included in the adjusted resource profits of the partnership but only the extent of the members share of such profits. ... Cameron Christine Savage (613) 347-1361 Co-ordinator, Resource Industries Attention: Zul Ladak 2004-006044 Hedging Gains / Losses of Partnership We are writing in response to your query regarding our memorandum dated December 9, 2003, wherein we provided comments in regard to certain Oil & Gas Audit Issue Sheets (our file 2003-00297). ...

7 May 1990 Income Tax Severed Letter RRRR341- Principal Issue Sheet — topic not mentioned Unedited CRA Tags none Principal Issue Sheet xxxxx Allan Nelson Resource Industries Issue xxxxx xxxxx xxxxx We advised Current Amendments of the Position that we were adopting, requesting them to inform Finance accordingly. Section Chief Resource Industries Section Rulings Directorate ...

17 June 2013 External T.I. 2013-0486901E5- Petroleum & Natural Gas Lease CRA Tags 66(15) "Canadian resource property" 66.4 Principal Issues: How is an amount received for granting a lease of rights to explore for, drill for or extract petroleum, natural gas or other hydrocarbons reported for income tax purposes? ... A Canadian resource property ("CRP") is defined under subsection 66(15) of the Income Tax Act (the "Act") as including any right, licence or privilege to explore for, drill for or take petroleum, natural gas or related hydrocarbons in Canada. ... Yours truly, Fiona Harrison, CPA, CA Manager, Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

However, the property may be considered Canadian resource property as per subsection 66(15), if the land value is principally attributed to the oil reserves. ... Consequently, the subsurface right owned by the taxpayer may qualify as a Canadian resource property. ... Manager Resources Section Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

30 April 1985 Income Tax Severed Letter 7-3785- [Reg. 1205(1) (b)—Class 10(k)—Tailings Pipes & Power Distribution Systems] April 30, 1985 HEAD OFFICE Resource Industries Section D. Lanos (613) 993-6201 RE: Reg. 1205(1) (b)- Class 10(k) Tailings Pipes & Power Distribution Systems This is in reply to your memorandum dated December 21, 1984 concerning the classification of the following assets used by XXXX in its mining operations in the above taxation years: 1) tailings pipes used to transport waste products from the smelter and refinery to the tailings pond; and 2) power distribution systems located at the mine site including power lines, underground cables, electrical substations, transformers, generators, circuit brakers and ancillary electrics. ... If anything, the above letter is more consistent with our amended position on tailings equipment, inasmuch as it recognizes that the transportation of ore to the sinter plant can form part of the extraction process just as we now recognize that the transportation of tailings to a tailings pond can form part of the "processing" of ore after extraction from a mineral resource. ...

15 October 2012 External T.I. 2012-0458201E5- Ontario FIT / microFIT Programs CRA Tags ITR 1100(27) ITR 1100(26) ITR 1100(29) ITR 1100(24) ITR 1100(28) ITR 1100(25) Principal Issues: Are there exceptions to the restrictions on the "specified energy property" rules in subsection 1100(24) to (29)? ... Nichols October 15, 2012 Dear XXXXXXXXXX: RE: Ontario FIT / microFIT Programs This is in response to your email of August 3, 2012, wherein you requested clarification of the response to question 8 of the Frequently Asked Questions (“FAQ’S”) relating to the Ontario's FIT / microFit Programs section of the Canada Revenue Agency website. ... Manager Resources Section Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

1 June 1991 Income Tax Severed Letter 91M06165 F- Canadian Exploration Expenses and Canadian Development | Expenses Unedited CRA Tags 66.1(6)(a), 66.2(5)(a), 66(12.62), 66(12.6), 66(10) Recommended Solution: 1)  Review of the Act: Canadian exploration expenses ("CEE") (defined in  paragraph 66.1(6)(a)) and Canadian development expenses ("CDE") (defined in paragraph 66.2(5)(a)) represent specific expenses incurred by a taxpayer.   ... In order to qualify as a valid renunciation under subsections 66(12.6) and 66(12.62), the resource expenditures must be incurred after the flow-through share agreement has been entered into. ... Proposed subsection 66(10) will prevent the "warehousing" of resource expenditures incurred prior to the existence of a flow-through share agreement. ...