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21 November 1990 Internal T.I. 9029437 F- Resource Expenses of a Limited Partner Unedited CRA Tags 96, 66.8   November 21, 1990 G.C. Hoard Resource Industries Chief of Audit Section Calgary District Office J. ... You mentioned the following points: 1.     Under section 66.8 of the Act, resource expenses of a limited partner are restricted to the at-risk amount of the limited partner. 2.      ...

5 May 1989 Income Tax Severed Letter AC57814- Resource Expenses of Limited Partner Current Amendments & Rulings Directorate Regulations Division Resource Industries Section B. ...

8 November 1990 Internal T.I. 9030847 F- Recapture of Resource Allowances Taking Place at Partnership Level Unedited CRA Tags 59(3.3), 1206(3), 96(1)(d), 65(1)   November 8, 1990 MEMO TO FILE Resource Industries   Section   J. Shaw   957-8968   7-903084 SUBJECT:  Question 16, 24(1) Liaison Meeting- November 20, 1990 Issues (a)     Whether the provisions of subsection 59(3.3) apply to a partnership or to its members, and (b)     Whether, if all of the partners who were such when the original costs were incurred are replaced, the answer is any different. ... This position ensures that recapture of the various resource allowances takes place which result conforms with the policy intent underlying subsection 59(3.3). ...

7 October 1990 Income Tax Severed Letter- Deductible Crown Rentals and Resource Profits Unedited CRA Tags Reg. 1204, 1204(d) Oil & Gas Issue Report # O&G 02 Deductible Crown Rentals and Resource Profits This is in reply to your memorandum dated September 26, 1990 wherein you request confirmation that the answer to a question (Question 21) regarding whether the tax treatment of certain lease rentals, which was prepared by the Rulings Directorate for the 1988 Rountable of XXX reflects the Directorate's current position with respect thereto. We confirm that there has been no change in the Directorate's position which was provided in the answer to question 21 of the 1988 Rountable of XXX Our understanding of the audit policy in your Oil and Gas Issue Report # O&G 02 is that Crown rentals which are deductible by virtue of Regulation 1211(d) should reduce resource profits computed under the provisions of Regulation 1204. ... Consequently, the second sentence in O&G 02 under Department's Policy should be replaced by "Since the potential source of income of non-producing properties would generally be from production, the deductible Crown rentals should reduce resource profits in the calculation of the resource allowance. ...

28 November 1989 External T.I. 58850A F- Diamonds Deposits- Mineral Resource Unedited CRA Tags 248(1) 19(1) G.R. White   (613) 957-8585   File No. 5-8850 November 28, 1989 Dear Sirs: Re:  Diamonds Deposits- Mineral Resource We are writing in reply to your letters dated October 10 and 16, 1989, in which you requested certification that any diamond deposits discovered in kimberlite pipes as a result of an exploration program of 24(1) would qualify as a mineral resources as defined in subsection 248(1) of the Income Tax Act (the "Act"). ... Yours truly Chief Resource Industries SectionBilingual Services and Resource Industries DivisionRulings Directorate ...

7 March 1991 Income Tax Severed Letter- Saskatchewan Capital Tax- Resource Surcharge Unedited CRA Tags 18(1)(m) Subject: Industry Issue Report # 5 Saskatchewan Capital Tax- Resource Surcharge ("Resource Surcharge") We are writing in reply to your memorandum of January 16, 1991, in which you requested our confirmation that the positions relied upon by you which are reflected in report #5 are current policies of Rulings in regards to the issue of whether paragraph 18(1)(m) is applicable to Resource Surcharges. ... The sentence under the heading of "Tax Implications" should be amended to reflect the tax implications affecting both income and resource allowance. ... For both earned depletion and resource allowance purposes, the former type of tax would be deductible in computing resource profits while the later type of tax would not be. 2. ...

Company B owns a royalty interest in respect of the production from this resource property. ... He wrote at the same place "The expressions "disposed of ", "lost" or "destroyed" were dealt with in the Australian case of Hentey Howe P.T.V. ... Yours truly, Chief Resource Industries Section Bilingual Services & Resource Industries Division Rulings Directorate ...

12 June 1989 External T.I. 58170 F- Small Business Deduction and Resource Allowance Unedited CRA Tags 13(1), 25(7), 39(1)(a)(ii), 59(3.2)(c), 125(1), 129(4) aggregate investment income, 129(4.1), ITR 1204(1), 1210(1) 19(1) File No. 5-8170   Allan B. ... Subparagraph 39(1)(a)(ii) of the Act excludes gains from the sale of Canadian resource properties from capital gains treatment; and (ii)      The amount of the negative CCDE pool would be specifically excluded from being treated as income from for purposes of subparagraph 129(4)(a)(ii) of the Act, by virtue of the provisions of either paragraph 129(4.1)(b) or (c) of the Act. 2.     If in the general scenario outlined above, the sale of an oil and gas well resulted in the corporation having recaptured capital cost allowance, as defined in subsection 13(1) of the Act, it is our position that the amount of the recapture would be included in the company's computation of resource profits pursuant to subsection 1204(1) of the Regulations and would thereby be included in the calculation of the company's resource allowance provided for in subsection 1210(1) of the Regulations.       ...

8 November 1989 Income Tax Severed Letter AC73828- Integrated Sawmill & Pulpmill- M & P Deduction November 8, 1989 Carole Couin-Toussaint Rulings Directorate Director Frank Cillman Bilingual Services & Resource Industries Division 7-3828A Subject: Integrated Sawmill & Pulpmill- M & P Deduction The Special Audits Division has requested that we withdraw one of our previous opinions which states that "the transportation activity of woodchips between the sawmill and the pulpmill which occurs within an integrated operation, be included as a qualified activity within the meaning of section 5202 of the Regulations so that the capital and labour costs of transporting the chips be included in the calculation of the M & p deduction." Facts The facts which relate to that particular opinion are as follows: 24(1) The Law Subsection 125.1(1) of the Act which is the subsection authorizing the M & P deduction requires the calculation of a corporation's Canadian manufacturing and processing profits ("M & p profit") in order to determine its M & P deduction. ... Therefore, for the transportation of woodchips to be a qualified activity it must be "integrally and essentially" connected to the manufacturing and processing of pulp and paper. 21(1)(b) 24(1)24(1) 21(1)(b) 23 23 Recommendation 21(1)(a) Chief Resource Industries Section Bilingual Services and Resource Industries Division ...