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12 June 1992 Income Tax Severed Letter 9216395- Gulf Canada Decision- Resource Allowance Unedited CRA Tags Reg. 1204 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. ... SUBJECT: GULF CANADA DECISION- RESOURCE ALLOWANCE SECTION: REG 1204] 1992 CPTS ROUNDTABLE QUESTION 6. ... 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. ...

5 May 2003 Income Tax Severed Letter 2003-000323B70- CEE-DYKE Construction- Resource Profit Unedited CRA Tags 66.1(6) 9 1204 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... F.C.T. ((1946) 72 C.L.R. 634 at 648) Dixon J. of the High Court of Australia stated that the answer to whether an expenditure is on income or capital account, "... depends on what the expenditure is calculated to effect from a practical and business point of view rather than upon the juristic classification of the legal rights, if any, secured, employed or exhausted in the process. ... Ltd., supra, at p. 648, reminds us that the classification of such expenditures '... depends on what the expenditure is calculated to effect from a practical and business point of view rather than upon the juristic classification of legal rights...', supra. ...

5 May 2003 Internal T.I. 2003-000323B- CEE-DYKE Construction- Resource Profit Unedited CRA Tags 66.1(6) 9 1204 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... F.C.T. ((1946) 72 C.L.R. 634 at 648) Dixon J. of the High Court of Australia stated that the answer to whether an expenditure is on income or capital account, "... depends on what the expenditure is calculated to effect from a practical and business point of view rather than upon the juristic classification of the legal rights, if any, secured, employed or exhausted in the process. ... Ltd., supra, at p. 648, reminds us that the classification of such expenditures '... depends on what the expenditure is calculated to effect from a practical and business point of view rather than upon the juristic classification of legal rights...', supra. ...

Why mining taxes exceed resource allowance? 2. Are Ontario mining taxes imposed on a mineral resource extracted a) a tax on income; b) deductible under paragraph 20(1)(v) and Reg. 3900; and c) a deduction in computing resource profits? ... This position is indicated in Issue # 33 of the Mining Industry Audit Issues. ... As indicated in the mid amble before paragraph (d) of that Regulation, "... the taxpayer's incomes and losses are computed in accordance with the Act... ...

The distinctions between timber limits and timber resource properties are discussed in IT-481. ... Replacement of Timber Limit & Cutting Rights "If an original right to cut timber is replaced by a new right, is the original right disposed of for income tax purposes? ... Regulation 700 (1)(c) "What does '... as determined by the province...' mean? ...

14 September 1989 Income Tax Severed Letter AC58421- Renounciation of Resource Expenditures Incurred Prior to the Date of an Agreement in Writing 5-8421 Frank S. ... Paragraph 66(l5)(d.l) of the Act requires that this "written agreement" exist between the principal-business corporation and the purchaser of the flow-through share prior to the date the resource expenditures are incurred. ... Chief Resource Industries Bilingual Services and Resource Industries Division Rulings Directorate ...

Whether resource allowance is reduced by enhanced recovery expenses Position: 1. ... "concept of source of production in resource allowance provisions is broader than in legislation where "development" must be distinguished from "production" April 13, 2000 Calgary Tax Services Office Resource Industries Section Denise Dalphy Attention: Bharat Patel (613) 957-9231 Oil & Gas Specialist 991848 1999-001191 Costs of Tangible Capital Property This is in reply to you facsimile transmission of July 7, 1999 concerning submissions dated June 2 and 18, 1999 that you received from XXXXXXXXXX. ... John Chan, Manager Resource Industries Section Resources, Partnerships and Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch ...

25 April 2003 Internal T.I. 2002-0153267- Timber Resource Property Also released under document number 2002-01532670. ... On its tax return for the taxation year ended XXXXXXXXXX reported the following amounts with respect to the disposition of the timber cutting rights: Recaptured CCA- Timber Limit $ XXXXXXXXXX Capital gain- Disposition of Timber Limit $ XXXXXXXXXX Legislation Part XI of the Regulations includes the rules applicable for capital cost allowance ("CCA"). ... This is the case even though the XXXXXXXXXX right would otherwise be considered a timber resource property. ...

Gross resource profits includes income from the processing of ore from mineral resources. ... The definition of deposit in The Shorter Oxford English Dictionary (3rd. ed.) includes the following: "... something principal deposited, laid or thrown down; esp. matter precipitated from a fluid medium, or collected in one place by a natural process. ... Bethlehem Copper Corporation Ltd., 74 DTC 6502 (S.C.C.), Martland J. wrote for the court at page 6524 that "... the operation of a mine refers to the extraction of ore from the ore body. ...

Principal Issues: 1) Should the hedging gain be included in gross resource profits? ... In the Federal Court- Trial Division case of Cominco Ltd. (84 DTC 6535), the issue was whether income of a resource company should be included in "resource profits" for the purpose of calculating the resource allowance. ... Other comments As provided in our file # 2000-0036547, "the recapture provisions of the Act and Regulations are fundamentally adjustments to income of previous years and do not create, in the year of disposal of the asset, some new form or source of income". ...