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April 27, 2000 Bharat Patel Resource Industries Section Oil & Gas Specialist A. ... Legislation Paragraph 66.1(6)(a) of the Income Tax Act (the "Act") provides that a "Canadian exploration expense" ("CEE") includes any expense incurred after May 6, 1974 that is: "any expense including a geological, geophysical or geochemical expense incurred by the taxpayer (other than an expense incurred in drilling or completing an oil or gas well or in building a temporary access road to, or preparing a site in respect of, any such well) for the purpose of determining the existence, location, extent or quality of an accumulation of petroleum or natural gas (other than a mineral resource) in Canada," and paragraph 66.1(6)(d) provides that it includes "any expense incurred by the taxpayer after March, 1987 and in a taxation year of the taxpayer in drilling or completing an oil or gas well in Canada or in building a temporary access road to, or preparing a site in respect of, any such well" if one of the criteria outlined in subparagraphs 66.1(6)(i), (ii), (iii) or (iv) of the Act is satisfied. ... Manager Resource Industries Section Resources, Partnerships and Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch ...

SPEAKING NOTES FOR RICK BISCARO FOR GOODMAN PHILLIPS & VINEBERG & CHARTERED ACCOUNTANTS OF ONTARIO ROUND TABLE, MAY 27, 1998 Query Statutory changes- proposed section 18.1 of the Act (intent + a couple of examples) Notes Finance had policy concerns that in a broad range of businesses, investors would undertake to pay expenditures that would otherwise be expenses payable by the “vendor” (e.g., payroll, mutual fund selling commissions, film production services) in exchange for a right to receive future income, usually from the vendor’s operation. ... However, it will not include an income interest in a trust, a Canadian resource property or a foreign resource property. ...

En plus de la cause Canada Trust 85 dont vous faites référence nous avons analysé les causes Gulf Canada Resources Limited v. Her Majesty the Queen (93 DTC 5345((la cause « Gulf ») et la cause Anthony K. ... Signification du terme « principalement » 4. Le terme « principalement » figurant dans la définition d'un bien locatif au paragraphe 1100(14) signifie «essentiellement» ou « surtout ». ...

The computation of the taxpayer’s income under section 3 would be as follows: Paragraph 3(a) – total of incomes from all sources = $100 Paragraph 3(b) – net taxable capital gains = $0 Paragraph 3(c) – total of 3(a) + 3(b) amounts ($100) less subdivision e deductions ($75) = $25 Paragraph 3(d) – amount determined under 3(c) ($25) less current year losses ($100) = $0 As a result, the amount computed under paragraph 3(c) in this situation would be $25. ... For taxation years ending after 2020, the CRA’s assessing practice will take into account the above position for all types of successored resource pools. We note that, if transactions are undertaken to avoid the application of the above position to successored resource pools (including transactions undertaken to convert successored resource pools into regular resource pools that are not subject to the successor rules), in a manner that would frustrate the object, spirit and purpose of section 66.7 or any other provision of the Act, the CRA would consider the application of the GAAR to such transactions. ...

Recommended Solution: (1)       Review of the Act: There are no specific provisions within the Act which would disallow A from making the successor election  (paragraph 66.7(7)(e)) to transfer its resource pools to the third party. (2)       Identification of a Tax Benefit: A large proportion of the resource pool relates to the mining properties which will be retained by A.  ... Immediately thereafter, A sells its oil and gas business and A wishes to make a successor election under paragraph 66.7(7)(e) to transfer its resource pools to the third party.  ... Normally as a matter of Departmental policy, an apportionment of the resource pool costs between the mining properties and the oil and gas properties would be acceptable.  ...

Robert Clark of Natural Resources Canada to you in respect of this matter. Background Pursuant to paragraph 1104(7)(c) of the Regulations, “... all wells of a taxpayer for the extraction of material from a deposit of bituminous sands or oil shales that the Minister, in consultation with the Minister of Natural Resources, determines constitute one project, are deemed to be one mine of the taxpayer.” ... John Chan Manager Resource Industries Section Resources, Partnerships and Trusts Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch 2- 3- ...

28 October 2009 Internal T.I. 2009-0343291I7- Disclosure of Taxpayer Information Unedited CRA Tags s. 241(1)(a); 241(4)(a) & (e)(viii); & 241(4)(10) and s. 33.11(a) Old Age Security Act Principal Issues: Whether taxpayer information may be disclosed to HRSDC where an individual has been cashing his deceased father's old age security and CPP cheques and keeping the proceeds for himself. ... At issue, is whether officials of the Canada Revenue Agency may disclose taxpayer information to officials of Human Resources and Skills Development Canada. ... In light of the foregoing, taxpayer information may be provided to the Minister of Human Resources and Skills Development for purposes relating to the administration of the CPP and the OASA. ...

Reasons: Jurisprudence and previous interpretations November 29, 2012 Excise GST/HST Rulings HEADQUARTERS General Operations & Border Issues Income Tax Rulings Directorate Attention: Angela Stachowski L. ... Gulf Canada Resources Limited 96 DTC 6065 (FCA)("Gulf"). The Gulf case dealt with the calculation of income for purposes of the resource allowance. ... In my view, the equivalent of the prime metal stage for mineral production is that point where the production processes have produced a marketable, saleable commodity which meets the specifications of its consumers" When asked about a specific mineral resource we often consult with Natural Resources Canada in order to determine the prime metal stage or its equivalent for that particular mineral resource. ...

The right to mine for minerals in a mineral resource outside of Canada falls within subparagraph (b)(ii) of the definition of “foreign resource property” in subsection 248(1) of the Act. ... As such, it is our view that the right of a reporting entity to mine minerals in a mineral resource outside of Canada would be considered tangible property that is specified foreign property for purposes of section 233.3 of the Act. ... With respect to the cost amount of the mineral rights, the CRA has a longstanding position that the cost amount of foreign resource property is nil. ...

October 11, 2000 XXXXXXXXXX TSO Resource Industries Section XXXXXXXXXX A.A. ... ". In my view, this provision is to be interpreted as it would be understood in the mining industry, for which Parliament included Canadian exploration expense as defined in s/p (iii.1) as a benefit to attract investment in resource production. ... John Chan, CA Manager Resource Industries Section Resources, Partnerships and Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch ...