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In our view, this resource constitutes a relief provided by the State to people in need because of their state of health. ... [A]mounts paid when a space reserved by the public facility is not occupied by a user … are paid based on a review of the users' needs because the amount is calculated based on what the users would have needed if they had occupied the spaces. As regards the contribution of users … it could also constitute a social assistance benefit …. ...

However, a resource may receive may also receive an amount directly from the user. The Directorate stated: If an Individual receives an amount directly from a resource user, that amount will be excluded from the Individual's income only if the Individual can demonstrate that the amount received is a social assistance benefit received indirectly by the Individual under a federally or provincially legislated program, based on a means, needs and income test. ... For the purposes of subparagraph 81(1)(h)(i), we are of the view that the children's special allowance [so] paid … is not an amount of family allowance under the LAF and the payment of such an allowance would not preclude the exemption from the social assistance benefit that would otherwise qualify pursuant to paragraph 81(1)(h). ...

21 May 2014 External T.I. 2014-0528021E5- Classification of Timber Limits-- summary under Schedule VI Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule VI timber limit v. timber resource property Standing timber is harvested and the land is subsequently disposed of at a gain. CRA stated: Generally a right not categorized as a "timber resource property" will be a timber limit. ... Timber limits usually include, among others, the right to cut which arises from the ownership of private land with timber. … [T]he cost of land with standing timber characterized as a timber limit would be more appropriately included in Schedule VI rather than under Class 15 of Schedule IV…. ...

1 March 2016 Internal T.I. 2016-0631181I7- Specified foreign property- mineral rights-- summary under Specified Foreign Property Summary Under Tax Topics- Income Tax Act- Section 233.3- Subsection 233.3(1)- Specified Foreign Property mineral right is real property which is intangible property After noting that 2014-0522241I7 indicated that a right to mine for minerals in a mineral resource outside Canada falls within s. (b)(ii) of “foreign resource property” in s. 248(1), that “for such mineral right to be considered specified foreign property, the right would have to be tangible property, which is understood to include real property such as land and rights issuing out of, annexed to and exercisable within or about land,” and that the mineral right would be considered a tangible property coming within s. (b) of 233.3(1) – “specified foreign property,” CRA stated: We wish to clarify that a specified foreign property can include inter alia tangible or intangible property…., real property can include… intangible property…[and] a mineral right would likely be considered an intangible property. ...

Carried on"): Respecting the exclusion in Article XIII, paragraph 4 of the Canada-Netherlands Convention for property (other than rental property) in which the business of the company is carried on, RC stated that in its view "Oil & Gas reserves and royalty interests will be excluded from the definition of immovable property... if the owner is actively engaged in the exploitation of natural resources and if such assets are actively exploited or kept for future exploitation by such owner.... [A]s a general rule, in order for a company to be 'actively engaged' in the exploitation of natural resources, the company must be directly involved in the management and daily activities of the exploitation process on a regular, continuous and substantial basis, and the company's employees must devote time, work and energy to the exploitation. ...

29 November 2022 CTF Roundtable Q. 2, 2022-0950501C6- Section 116 and Taxable Canadian Property-- summary under Subsection 116(5) Summary Under Tax Topics- Income Tax Act- Section 116- Subsection 116(5) CRA generally will not provide advance guidance on TCP status The determination of whether for shares of a private corporation, interests in a partnership or interests in a trust are TCP can be complicated because it must be determined if at any time in the previous 60-month period more than 50% of the fair market value of the share or interest was derived directly or indirectly from real or immovable property, Canadian resource properties, timber resource properties and options or interests in these properties. ... Although the Income Tax Rulings program is there to provide advance comfort on the tax consequences of a transaction, as noted in IC70-6R12, CRA will not confirm the fair market value of a property, and the Rulings program is not in a position to verify the facts provided – and there are also timing considerations. ...