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26 October 1989 Internal T.I. 58899 F- "Mineral Resource"- Subsection 248(1) Unedited CRA Tags 248(1) mineral resource Director General   Tax Policy Analysis Division File No. 5-8899 Energy Mines & Resources Canada G.R. ... Schell Director Mining Tax Legislation Interpretation Division October 26, 1989 Dear Sirs: Re:  24(1) Mineral Resource Subsection 248(1) of the Income Tax Act We are writing to request your certification that the 24(1) 24(1) is a mineral resource as that term is defined under subparagraph (d)(i) of the definition in subsection 248(1) of the Income Tax Act. ...

28 February 1991 Internal T.I. 9023937 F- Computation of Resource Profits Unedited CRA Tags 124.1(1),125.1(3)Canadian manufacturing and processing profits, ITR 1204(1), 1210(1)(a)(i), 1206(1), 1204(1)(b)(ii)(A)                        Feb 28, 1991 Special Audits Division                 Resource Industries E.H. ... The amount of the resource allowance which a taxpayer may claim is computed under section 1210 of the Regulations by reference at subparagraph 1210(1)(a)(i) thereof to, inter alia,       "(i) his resource profits for the year (within the meaning assigned by subsection 1204(1) if that subsection were read without reference to paragraph (a) or subparagraph (b)(iv) thereof...". 11.     Without restating the Regulation 1204(1) definition of resource profits as modified by Regulation 1210(1)(a)(i), the portions of the definition which are relevant to  24(1) are       1204(1) For the purposes of this Part, "resource profits" of a taxpayer for a taxation year means the amount, if any, by which (b)  the amount, if any, of the aggregate of his incomes for the year from (ii)      the production and processing in Canada of (A)      ore, other than iron or tar sands ore, from mineral resources in Canada operated by him to any stage that is not beyond the prime metal stage or its equivalent, exceeds (c)       the aggregate of his losses for the year from the sources described in paragraph (b) computed in accordance with the Act, on the assumption that he had during the year no incomes or losses except from those sources. 24(1) EMR 13.      ...

19 October 1990 Internal T.I. 9026877 F- Deductible Crown Rentals and Resource Profits Unedited CRA Tags 1211(d), 1204   October 19, 1990 Audit Programs Directorate Resource Industries Special Audits Division Section E.H. ... 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". 4.      ...

2 November 1989 Internal T.I. 58197 F- Warehousing of Resource Expenditures Unedited CRA Tags 66(12.6), 66(15) principal-business corporation, 66(15) flow-through share, 66.1(6)(a)(iv)   November 2, 1989 GAAR Committee Resource Industries   Section   Allan B. Nelson   957-8984   File No. 5-8197 Subject: Warehousing of Resource Expenditures Issue Whether GAAR would apply to deny a resource company's renunciation of resource expenditures to Its flow-through share Investors In a scenario where the sole purpose of using a particular partnership arrangement was to facilitate the resource company's warehousing of the resource expenditures until it decided if flow-through share agreements would be entered into. ... These warehousing arrangements could take various forms, for example: (i)       A limited partnership enters into flow-through share arrangements with resource companies.  ...

The royalty constitutes a Canadian resource property pursuant to subparagraph 66(15)(c)(v) of the Act, 3.      ... Thus, the payment would not be included in the computation of eligible resource profits for purposes of sections 1204 and 1210 of the Regulations.       ... Thus, the payment would reduce resource profits computed for purposes of section 1210 of the Regulations.       ...

F2959 F- Resource Industries Unedited CRA Tags 66.8(2)     October 23, 1989 Ms. ... Burnett/957-2078 Resource Industries Division   File No. F-2959 Subsection 66.8(2) of the Income Tax Act This is in response to the memorandum of May 5, 1989 prepared by F. ...

19 November 1990 Internal T.I. 9030467 F- Hedging Gains Resource Allowance Unedited CRA Tags n/a   November 19, 1990 E.H. ... Shaw   957-8968 Attention: S. Lakhani   7-903046 SUBJECT:  Hedging gains Resource Allowance This is in reply to your memorandum of October 29, 1990 in which you requested our confirmation that Brian Dawe's July 8, 1983 memorandum setting out an "administrative position" that hedging gains and losses would be taken into account in computing resource profits for the purposes of the resource allowance deduction where the hedge is satisfied by a delivery of the hedger's production was, and remains, in accordance with our views of the law. ... HMQ 84 DTC 6535-     Gunnar Mining Limited v. MNR 68 DTC 5035-     Guthrie v. ...

15 November 1990 Internal T.I. 9030887 F- Resource Allowance Unedited CRA Tags 1210(a)(i)(B)   November 15, 1990 Mr. ... D'Aurelio Resource Industries Director Section Current Amendments and J. ... Burnett your file  NQF-3377   our file 7-903088 SUBJECT:  Clause 1210(a)(i)(B) of the Income Tax Regulations In reply to your memorandum of October 29, 1990, we intend to support Finance's position on the issue relating to the above identified in our memorandum of October 30, 1989 to you. ...

1 December 1989 Internal T.I. 58899A F- Mineral Resource Unedited CRA Tags n/a 19(1) 5-8899   G.R. White   (613) 957-8585 December 1, 1989 Dear Sirs: Re:  Mineral Resource 24(1) We are writing in reply to your letters dated October 13 and 20, 1989, in which you requested certification 24(1) Yours truly, Section ChiefResource Industries SectionBilingual Services and ResourceIndustries DivisionRulings Directorate ...

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.      ...