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15 June 2006 External T.I. 2006-0183921E5- Definition of Canada & Reg.105 Unedited CRA Tags 255 Reg.105 Principal Issues: (1) Whether the work done by NRco could be considered to be "in connection with the exploration for or exploitation of the minerals..." for the purposes of 255(b) of the Act simply because the main purpose of the work done is to determine whether Canada has the right to the resources under UNCLOS? ... Question 1 1-) Section 255 of the Act & Section 105 of the Regulations The term " Canada" is not defined in the Income Tax Act. ...

7 July 1991 Income Tax Severed Letter- Offshore activities tax treatment — Canada-U.K. tax treaty and Canada-Netherlands tax treaty Unedited CRA Tags Canada–U.K. ... What are to be considered activities that would be carried on in Canada in connection with the exploration or exploitation of the sea bed and subsoil and their natural resources ("in connection with the offshore resources")? ... Transportation activities (e.g. ferrying of supplies and personal) in connection with the offshore resources fall within paragraph 2 of Article XXVIIA. ...

Reasons: The definition of SR & ED specifically excludes certain mining activities as qualifying for SR & ED. ... Generally, these paragraphs describe expenditures relating to the exploration or development of Canadian resource property, which includes rights to prospect, explore, drill and mine for minerals in a Canadian mineral resource. ... Yours truly, Fiona Harrison, CPA, CA Manager Resources Section Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs ...

3 June 1985 Income Tax Severed Letter 5-7656- [] XXXX P.K. Tang (613) 995-1787 XXXX June 3, 1985 Dear Sirs: Re: Subsection 111(5) of the Income Tax Act This is in reply to your letter of April 19, 1985 wherein you request our view with respect to the application of subsection 111(5) of the Income Tax Act (the "Act") as it relates to the following situation: A Co. is a company that carried on a resource business. ... A Co. continues to own investments and non-producing resource properties. ... Although, as you stated in your letter, the interest income received by A Co. may be deemed to be income from a business by virtue of subsection 129(6) and the pension refund can be said to be related to the company's business carried on prior to the acquisition of control, the company did not, after the control was acquired by the other person, continue to carry on the resource business that gave rise to the loss. ...

23 March 1990 Income Tax Severed Letter AC74656- Capital Cost Allowance- Investment Tax Credit- M & P Tax Deduction Unedited CRA Tags 127(9), Reg. 1100, 1104, 4601, 5201, Sch. ... The RDIA defines "facility" as the structures, machinery and equipment that constitute the necessary components of an M&P operation, OTHER THAN an initial processing operation in a resource-based industry. ... One of the activities contained in those subparagraphs is the extraction of minerals from a mineral resource and in our opinion this would include 24(1) 2. ...

2005 Ruling 2005-0149001R3 F- Underground Exploration Program- New Mine & CEE Unedited CRA Tags 66.1(6) 66.2(5) 248(1) "Mineral Resource" Principal Issues: A) Whether expenses relating to an underground exploration program to be carried out will be related to a mine that has come into production in reasonable commercial quantities, or to a potential or actual extension thereof. ... Dans sa totalité, le Projet Souterrain nécessitera des investissements estimés à XXXXXXXXXX $. ... Les coûts estimés pour la seconde phase de forage sont évalués à XXXXXXXXXX $ totalisant XXXXXXXXXX mètres en forage XXXXXXXXXX. 9. ...

2006 Ruling 2006-0206021R3 F- Underground Exploration Program- New Mine & CEE Unedited CRA Tags 66.1(6) 66.2(5) 248(1) "Mineral Resource" Principal Issues: A) Whether expenses relating to an underground exploration program to be carried out will be related to a mine that has come into production in reasonable commercial quantities, or to a potential or actual extension thereof. ... Dans sa totalité, le Projet Souterrain nécessitera des investissements estimés à XXXXXXXXXX $. ... L'ensemble des travaux de forage sous terre totalisera XXXXXXXXXX mètres en forage pour un coût total maintenant estimé à XXXXXXXXXX $. 8. ...

" In another speech given at the same tax conference (reproduced at pages 18 and 19 of the aforementioned book) Mr. ... In the context of the resource allowance, cases such as Cominco Ltd. v. ... Yours truly, for Director Resources, Partnerships and Trusts Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ...

2000 Ruling 1999-0012763- Class 43-1 System & Heat Rate Requirements Unedited CRA Tags class 43-1 1104(14) 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. ... Reasons: (a) Based upon the opinion of Natural Resources Canada dated XXXXXXXXXX, Plant XXXXXXXXXX for the purpose of subparagraph (c)(i) of Class 43.1 in Schedule II of the Regulations. ... Yours truly, for Director Resources, Partnerships and Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch ...

Resource Taxation- Crown Lease Rentals/ 24. Principal Business Corporation Renunciations/ 25. ... The grossed-up total of withholding tax is calculated by applying the following formula: Required payment = tax rate X interest payment 100 minus tax rate For example, the required payment of withholding tax on an interest payment of $1,000, assuming a withholding rate of 15%, would be calculated as follows: 15 X $1,000 = $176.47 (100- 15) Canada-U.S. ... Department's Position The Department is presently studying the impact of the decisions in Hickman Motors and Mark Resources. ...