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Question 3:  there should be a comma after the word "required". 2.     Question 10, line 4:  the word "assets" is spelled incorrectly. 3.      ... Yours truly Section ChiefResource Industries SectionBilingual Services and Resource Industries DivisionRulings Directorate ...

March 11, 1997 Toronto Centre Tax Services Office Resource Industries Ms. Cathie Figueira Section Acting Assistant Director Peter Lee Verification & Enforcement (613) 957-8977 Attention: Ms. ... Acting Chief Resource Industries Section Resources, Partnerships and Trusts Division Income Tax Rulings and Interpretation Directorate Policy and Legislation Branch c.c. ...

July 15, 1998 Employer Services Resource Industries Other Programs Section A. ... In those situations where XXXXXXXXXX does make advances to XXXXXXXXXX, the FTS Agreement provides that the advances shall be allocated as follows: “ XXXXXXXXXX XXXXXXXXXX,” Section 3 of the FTS Agreement provides that XXXXXXXXXX agrees to incur Canadian exploration expenses (“CEE”) and/or Canadian development expenses (“CDE”) “in an amount equal to or lower than the 1998 Advances” received from XXXXXXXXXX and that it will issue flow-through shares, at a price of $XXXXXXXXXX per share, in an amount equal to the amount of CEE/CDE actually incurred, ie. the amounts described in XXXXXXXXXX above. ... Manager Resource Industries Section Resources, Partnerships and Trusts Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch- 1- ...

The word " taxpayer" in those provisions should be interpreted as referring to a partner and not a partnership. ... The position is based on the scheme of the relevant resource provisions. ... The notes state that this subsection "... is introduced to clarify the tax treatment of a person (including a partnership) who is a member of a partnership involved in mining or oil and gas. ...

April 11, 1995 Saint John, New Brunswick Resource Industries Taxation Service Centre Section Audit Division B. ... Regulation 5201 describes M & P Profits as the ADJUBI for the year. ... Marsh & McLennan Ltd., 83 DTC 5180 (F.C.A.), Aqua-Gem Investments Ltd. v. ...

Beech, Chief of Audit Partnerships and Trusts     Division   C.R. Brown   (613) 957-8954   912047 24(1) Claim for Investment Tax Credit With reference to your letter of July 10, 1991 we reconsidered our views on the eligibility of a Canadian Controlled Private Corporation ("CCPC") which is a partner in a partnership to avail itself of the enriched level (35%) Investment Tax Credits with respect to the allocation of investment tax credit from the partnership to the CCPC. ... Rules against unreasonable allocations would be needed. c)     The enhanced investment tax credit for Canadian- controlled private corporations is an incentive to encourage a relatively small corporation to use its resources to incur the expenditures and accept the risks of performing scientific research and experimental development. In a typical partnership arrangement the committed resources of all the partners are available and the expenditures and risks are jointly assumed by the partners. ...

Previously, the CCRA would only consider an Indian band as a public body performing a function of government when one of the following conditions was met: · the Band had passed by-laws under both sections 81 and 83 of the Indian Act; or · the Band had reached an advanced stage of development as was formerly required by section 83 of the Indian Act. ... Question 4 Would the location of the resource covered under the XXXXXXXXXX (i.e., on or off reserve) affect the taxation of payments received under an XXXXXXXXXX? ... The location of the resource would have to be on the reserve to qualify for this tax exemption. ...

" In Bethlehem Copper Corporation Ltd (74 DTC 6520), the Supreme Court stated that "... there is a mine within the meaning of s. 83(5) if there is a body of ore together with the workings, equipment and machinery capable of producing it. ... Prior to March 6, 1996 the definition of 'income from a mine' in paragraph 1104(5)(a) required all of the ore processed by the taxpayer to be from a mineral resource owned by the taxpayer. ... For Director Reorganizations and Resources Division Income Tax Rulings Directorate Policy and Legislation Branch ...

February 12, 2015 Charities Directorate CRA HEADQUARTERS 7th Floor, Place de Ville, Tower A Income Tax Rulings 320 Queen Street Directorate Ottawa ON K1A 0L5 Lori Merrigan (613) 957-9229 2014-054729 Attention Ann Rénoüs Policy, Planning and Legislation Division Advice to Charities on 149(1)(c) – Chief's Council This is in response to your e-mail request of September 23, 2014, for advice concerning the interpretation of paragraph 149(1)(c) of the Income Tax Act (the "Act"). ... Recreational, cultural, social, economic and human resource development services to all member bands. For example: Social development services are provided to XXXXXXXXXX member bands, including: Basic Income Assistance; Person with Persistent Multiple Barriers; Persons with Disabilities; Monthly Nutritional Supplement; Adult In-Home Care; and Child Out of Parental Home; Human resource development programs that include the Labour Market Initiative, the Targeted Wage Subsidy and the Workplace Based Training programs, skill development and training programs, the Student Career Placement and the Youth Initiative Programs; Employment services that provides an Aboriginal Career Training Team program; Economic development programs such as marketing and promotional organization for the Council, business investment programs and joint venture opportunities; and Language and cultural programs. ...

Beith Office (2)AuthorSection ChiefResearch File Corporate Case File orSubject File Return to Rulings, Room 400 Met.   ... In the last paragraph of your letter you suggest that GAAR will not be applicable if the taxpayers are making a reasonable apportionment of the resource pools between the mining business and the oil and gas business.  ... Beith Acting Assistant Deputy MinisterLegislative and Intergovernmental Affairs Branch c.c.:       B. ...