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11 July 2002 External T.I. 2002-0126795 F- RESSOURCES INTERMEDIAIRES REVENU EX-- summary under Paragraph 81(1)(h) Summary Under Tax Topics- Income Tax Act- Section 81- Subsection 81(1)- Paragraph 81(1)(h) contributions paid to a Quebec intermediate resource have been treated as means-based assistance CCRA noted: [W]e have determined in the past that a contribution paid by an institution to a family-type resource or an intermediate resource under the A ct respecting health services and social services was usually a social assistance benefit paid to an individual under a provincially legislated program, on the basis of a means, needs and income test. In addition, where a user has been referred to a family-type resource or an intermediate resource by a "public institution" under [such] Act … part of the user’s contribution may also constitute such a benefit. This would be the case, for example, for any portion of a user's contribution that comes from the guaranteed income supplement or spouse's allowance paid in accordance with the Old Age Security Act or that comes from amounts of last-resort financial assistance paid under the [Quebec] Employment Assistance Program …. ...

., physical, chemical or mechanical) characteristics of the mineral resource Regarding whether the test of incurring an expense “for the purpose of determining the existence, location, extent, or quality of a mineral resource” (the “CEE Purpose Test”) would generally include expenses for determining the economic feasibility of a deposit, such as expenses for preparing pre-feasibility or feasibility studies (including expenses for determining the cut-off grade of the deposit), market studies or studies for determining the anticipated long-term price of a mineral, based on an expansive interpretation of the word “quality,” CRA noted: “the word ‘quality’ could be capable of an interpretation that either includes the concept of commercial value or that instead focuses more narrowly on the physical or inherent aspects of a particular item having regard to the ejusdem generis rule, it was to be noted that “the first three words in the list in the CEE Purpose Test” referred to “the inherent physical characteristics of the mineral resource,” which suggested that the word the word “quality” should be similarly “limited to inherent characteristics of the mineral resource,” so that it “could encompass other inherent characteristics of the mineral resource such as its chemical composition or mechanical properties (e.g., strength or porosity).” various materials suggested that the purpose to the provision was “the search for, or discovery of, the minerals in the ground,” and that expenses related to “external factors, for example the cost of bringing a product to purchasers, including marketing and distribution costs … or to the overall assessment of economic viability through a pre-feasibility study or feasibility study, extend well beyond the focused nature of an incentive targeted at the activity of mineral exploration.” CRA concluded: [E]xpenses that qualify for CEE do not … include expenses for determining the economic viability of a mineral resource if those expenses do not relate to a determination of the natural (e.g., physical, chemical or mechanical) characteristics of the mineral resource. Such expenses are too remote to be described as expenses incurred for the purpose of determining the “quality” of a resource. ...

In finding that the remission was not available, the Directorate stated: [A] "Canadian resource property" does not constitute a TCP. A taxable capital gain from the disposition of a "Canadian resource property" is therefore not included pursuant to subparagraph 115(1)(a)(iii) …. [Furthermore] … it is highly doubtful that the Right can be considered real property …. ...

PEA The Company’s exploration on the property has focused both on expanding and upgrading existing resources related to the footprint of the old mine, as well as seeking new resources outside the known resource area. ... The results of the PEA warrant additional exploration to expand the potentially mineable resource by converting inferred resources to measured and indicated. ... Ruling Re the expenses of the proposed program qualifying under s. 66.1(6) – CEE- para. ...