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23 November 1989 Ruling 58941 F- "Cost Amount" of Canadian Resource Property Unedited CRA Tags 248(1) cost amount 19(1) File No. 5-8941   J. Chan   (613) 952-9019 November 23, 1989 Dear Sirs: Re:  Request for Technical Interpretation "Cost Amount" of Canadian Resource Property We are writing in reply to your letter dated October 18, 1989, wherein you requested our interpretation of the meaning of "cost amount" of Canadian resource property for purposes of the Income Tax Act (the "Act"). As you indicate, the relevant provision of the Act to determining the cost amount of Canadian resource property is paragraph (f) of the definition of "cost amount" in subsection 248(1) which states that "cost amount" to a taxpayer of a property at any time means.       ...

20 April 1990 Internal T.I. 59269 F- Non-capital Loss Created by Resource Expenditures Unedited CRA Tags 3(a), 3(b), 3(c), 66.1(3), 66.2(2), 111(8) non-capital loss 19(1) File No. 5-9269   Frank S. Gillman   (613) 957-8953 April 20, 1990 Dear Sirs: Re: Non-Capital Loss created by Resource expenditures We are writing in reply to your letter of December 8, 1989 wherein you requested our opinion as to whether a taxpayer is permitted under the Income Tax Act (the "Act") to create a non-capital loss by claiming various resource expenditures, assuming that these resource expenses are referable to a source of income and not claimed under subdivision e of Part 1 of the Act, as provided by subsection 3(c) of the Act.  ... With regards to whether income from a source is property or business, each individual income item must be examined as this is a question of fact. for the Director Bilingual Services and Resource Industries DivisionRulings Directorate ...

12 June 1990 Ministerial Letter 59768 F- Canadian Resource Property and Qualified Farm Property Unedited CRA Tags 9, 39, 45(1)(a), 54 capital property, 59(3.2)(c), 66(15) Canadian resource property, 66.2(5), 66.4(5), 110.6 24(1) File No. 5-9768   John Chan   (613) 952-9019 19(1) June 12, 1990 Dear Sirs: Re:  Request for Technical Interpretation- Canadian Resource Property and' Qualified Farm Property under the Income Tax Act (the "Act") We are writing in reply to your letter dated March 12, 1990, wherein you requested a technical interpretation of the meaning of Canadian resource property ("CRP") and qualified farm property under paragraph 66(15)(c) and subsection 110.6(1) of the Act, respectively, in relation to a hypothetical situation herein described. ... Question 3 Can the character of the property change from being a Canadian resource property to something else? ... Further, section 45 may be irrelevant because a CRP is not a capital property.  2.      ...

9 July 1993 External T.I. 9303275 F- Wind-up of Corporation Owning Canadian Resource Property Unedited CRA Tags 66(15) Canadian resource property, 66(15) joint exploration corporation, 66.7(10), 80(1), 80(3), 88(1) XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: RE:  Wind-up of corporation owning Canadian Resource Property This is in reply to your letter of February 1, 1993 wherein you requested a technical interpretation concerning a number of questions arising in the above circumstances. You have described a situation where the facts are as follows:-     A parent company ("Parentco") owns all the issued shares of a subsidiary company ("Subco").-     Each of Parentco and Subco is a taxable Canadian corporation ("TCC"), within the meaning assigned that phrase in paragraph 89(1)(i) of the Income Tax Act (the "Act").-     Subco's only asset is a Canadian resource property (the "CRP"), within the meaning assigned that phrase in paragraph 66(15)(c) of the Act, which has a fair market value ("FMV") of $XXXXXXXXXX-     Parentco has a loan receivable from Subco (the corresponding loan payable representing Subco's only liability) which has a face value of $XXXXXXXXXX but an adjusted cost base ("ACB"), within the meaning assigned that phrase in paragraph 54(a) of the Act, of nil.-     The ACB to Parentco of the loan receivable from Subco was reduced in prior years as a consequence of the renunciation of resource expenditures by Subco at a time when it was a joint exploration corporation, within the meaning assigned that phrase in paragraph 66(15)(g) of the Act.-     Subco is wound up into Parentco.-     Prior to the winding-up of Subco, control of Parentco (and Subco) was acquired such that the provisions of subsection 66.7(10) of the Act applied to deem each of Parentco and Subco to be a "successor".-     Parentco had cumulative Canadian development expense ("CCDE"), within the meaning assigned that phrase in paragraph 66.2(5)(b) of the Act, in the amount of $XXXXXXXXXX from the acquisition of other resource property prior to the above acquisition of control. You have asked the following questions with regard to this situation: 1.      ...

Since they are not deductions in computing income from a business, they cannot be deducted in calculating gross resource profits or resource profits for resource allowance purposes. ... Amounts determined under paragraph 12(1)(v) of the Act with respect to a negative Scientific Research and Experimental Development (SR & ED) pool balance. 3. ... To the extent that the amounts are in respect of SR & ED amounts that were deducted under subsection 37(1) of the Act in computing gross resource profits in prior years, we agree with your position that amounts included in income under paragraphs 12(1)(t) or (v) of the Act should be included in income for the year from production and/or processing in computing gross resource profits, and consequently, in the calculation of the resource allowance under subsection 1210(1) of the ITR. ...

Position TAKEN: Provincial capital tax paid should be allocated between resource and non-resource activity and capital tax attributed to resource activity would be a deduction for determining resource profit. ... July 28, 1995 Audit Technical Support Division Resource Industries Industry Specialist Services Section B. ... Cloutier 7-951496 Capital Tax- Resource Profits Calculation We are writing in response to your June 2, 1995 request for our opinion on whether producers in the Oil & Gas and Mining Industries should be required to allocate provincial capital tax between resource and non-resource activities and deduct the capital tax attributed to resource activity in determining resource profits as defined in Regulation 1204. ...

11 January 1990 External T.I. 74320 F- Partnerships and the "Successor" Rules and Partnerships and Resource Allowance Unedited CRA Tags 96(1), 1210(2), 20(1)(v.1), 1204(1)   January 11, 1990 E.H. ... Under those rules, where a taxpayer held any interest in a resource property, no matter how small, and increased its interest in the resource property, or acquired the balance of the resource property could also be sheltered by a claim with respect to the successored pools. ... DirectorBilingual Services and Resource Industries DivisionRulings Directorate ...