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22 November 2011 External T.I. 2011-0420451E5 F- Canadian resource property Unedited CRA Tags 66.2(5); 66(15); 66(12.1) Principal Issues: 1. ... General information provided assuming that the right acquired is Canadian resource property. General information also provided assuming that the right acquired by the purchaser is not Canadian resource property. ...

23 March 2011 Internal T.I. 2010-0389081I7 F- Disposition of a resource property Unedited CRA Tags 66.2(5); 66.1(6) Principal Issues: 1. At what time the resource property was transferred by the Vendor to the Purchaser? ... Comme mentionné dans XXXXXXXXXX E 2010-0370781I7, la définition de " sale price " selon le Dictionnaire " Dictionary of Canadian Law " est la suivante: Sale price. 1. ...

13 March 2013 Internal T.I. 2013-0480511I7 F- Canadian resource property CRA Tags 66.2(5) Principal Issues: Whether an amount paid to XXXXXXXXXX for the purpose of obtaining a licence to explore a mineral resource in Canada is a Canadian development expense. ... Reasons: It is part of the cost of a property described in paragraph (b) of the definition "Canadian resource property" in subsection 66(15). ... De plus, ce montant devrait faire partie de l'élément A de la définition de « frais cumulatifs d'aménagement au Canada » prévue au paragraphe 66.2(5) de la Loi. ...

10 October 1989 Ruling 57863 F- Termination of Flow-through Share Agreement Prior to Resource Company Incurring and Renouncing Promised Amounts Unedited CRA Tags 66(12.73), 66(15) flow-through share ITR 6202.1 19(1) File No. 5-7863   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 otherwise 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. ... (i)     to provide assistance, (ii)       to make a loan or payment, (iii)       to transfer property, or (iv)       otherwise to confer a benefit by any means whatever, including the payment of a dividend, either immediately or in the future, that may reasonably be considered to be, directly or indirectly, a repayment or return by the corporation... of all or part of the consideration for which the share was issued... ...

27 June 2018 External T.I. 2018-0742881E5 F- Royalties under Canada Petroleum Resources Act Unedited CRA Tags 9, 18(1)a), 18(1)m) revoked Principal Issues: Whether royalties paid under the Canada Petroleum Resources Act are considered to be an expense deductible in computing business income. ... (ci-après la « LFH »). À moins d’indication contraire, tous les renvois législatifs dans la présente sont des renvois aux dispositions de la Loi de l’impôt sur le revenu, L.R.C. (1985), c. 1, (5e suppl.), (ci-après la « Loi »). ... La LFH et le Règlement caractérisent les montants à verser, par un assujetti, de « redevances ». ...

14 September 1989 Ruling 58421 F- Renunciation of Resource Expenditures Incurred Prior to the Date of an Agreement in Writing Unedited CRA Tags 66(12.6), 66(12.62), 66(12.64), 66(15) flow-through share 19(1) File No. 5-8421   Frank S. Gillman   (613) 957-8953 September 14, 1989 Dear Sirs: Re:  Agreement in writing Paragraph 66(15)(d.1) of the Income Tax Act (the "Act") This is in reply to your letter dated July 19, 1989, in which you requested our opinion regarding our interpretation of paragraph 66(l5)(d.1) of the Act as it relates to the issue of whether resource expenditures incurred prior to the date on which an agreement is entered into in writing can be renounced pursuant to the flow-through share provisions of the Act. ... The aforesaid subsections may be paraphrased as follows in stating the requirement as to when a principal-business corporation has to incur the various expenses so that they qualify for "flow through" purposes:      "... and, during the period commencing on the day the agreement was entered into and ending 24 months after the end of the month that included that day, the corporation has incurred (the specific expense), the corporation may..., renounce,..., by which those expenses incurred by it during that period... ...

2009 Ruling 2008-0292141R3- ruling- foreign resource property Unedited CRA Tags 66(16) Principal Issues: 1.Will the Net Smelter return taken back on sale of shares constitute a foreign resource property? ... The other shareholders in XXXXXXXXXX are XXXXXXXXXX, which holds XXXXXXXXXX % of the shares of XXXXXXXXXX, which holds the remaining XXXXXXXXXX %, both directly and via XXXXXXXXXX. 5. ... The Corporation has maintained its current ownership of XXXXXXXXXX % (directly and indirectly) since XXXXXXXXXX. 7. ...

Nelson Resource Industry Section 957-8984 SUBJECT: FILE Proposed Part 1.3 of the Income Tax Act Tax on Large Corporations Resource Industry Issues Overview New Part 1.3 of the Act, as passed by the House of Commons on December 20, 1989, proposes to levy a 0.175% annual tax on a corporation's capital employed in Canada in excess of $ 1O million. ... Section 181.5 of the Act provides that the canital deduction of a corporation for a taxation year is $ 10 million. It also provides for a sharing of the $ l0 million amount between related corporations. ...

2 April 1990 Income Tax Severed Letter 0-0350- Proposed Part 1.3 of the Income Tax Act—tax on large corporations resource industry issues Unedited CRA Tags 181.1, 181.2, Reg. 8600 Overview New Part 1.3 of the Act, as passed by the House of Commons on December 20, 1989, proposes to levy a 0.175% annual tax on a corporation's capital employed in Canada in excess of $ 10 million. ... Section 181.5 of the Act provides that the capital deduction of a corporation for a taxation year is $ 1O million. ... To assist us in replying to a query recently received from the Calgary District Office (our file #7-4766), A Nelson of the Resource Industries Section posed the following queries relating to the Oil and Gas Industry: XXX ...

July 17, 1997 Calgary Tax Services Office Resource Industries Graham Hoard Section Acting Assistant Director Peter Lee Verification & Enforcement (613) 957-8977 Attention: Doug Reeh Large File Case Manager 7-970054 XXXXXXXXXX Terminal Loss and Resource Allowance This is in reply to your memorandum of January 2, 1997 wherein you requested our opinion on whether a terminal loss of $XXXXXXXXXX resulting from the disposition of its mining assets by the corporation formed in an amalgamation of XXXXXXXXXX, should be disallowed in computing the amalgamated corporation's income under the Income Tax Act (the "Act"). ... There is no requirement that this negative resource profits of XXXXXXXXXX must be offset against any resource profits of XXXXXXXXXX under the Regulations. ... Acting Chief Resource Industries Section Resources, Partnerships and Trusts Division Income Tax Rulings and Interpretation Directorate Policy and Legislation Branch ...