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Why mining taxes exceed resource allowance? 2. Are Ontario mining taxes imposed on a mineral resource extracted a) a tax on income; b) deductible under paragraph 20(1)(v) and Reg. 3900; and c) a deduction in computing resource profits? ... This position is indicated in Issue # 33 of the Mining Industry Audit Issues. ... As indicated in the mid amble before paragraph (d) of that Regulation, "... the taxpayer's incomes and losses are computed in accordance with the Act... ...

Whether resource allowance is reduced by enhanced recovery expenses Position: 1. ... "concept of source of production in resource allowance provisions is broader than in legislation where "development" must be distinguished from "production" April 13, 2000 Calgary Tax Services Office Resource Industries Section Denise Dalphy Attention: Bharat Patel (613) 957-9231 Oil & Gas Specialist 991848 1999-001191 Costs of Tangible Capital Property This is in reply to you facsimile transmission of July 7, 1999 concerning submissions dated June 2 and 18, 1999 that you received from XXXXXXXXXX. ... John Chan, Manager Resource Industries Section Resources, Partnerships and Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch ...

25 April 2003 Internal T.I. 2002-0153267- Timber Resource Property Also released under document number 2002-01532670. ... On its tax return for the taxation year ended XXXXXXXXXX reported the following amounts with respect to the disposition of the timber cutting rights: Recaptured CCA- Timber Limit $ XXXXXXXXXX Capital gain- Disposition of Timber Limit $ XXXXXXXXXX Legislation Part XI of the Regulations includes the rules applicable for capital cost allowance ("CCA"). ... This is the case even though the XXXXXXXXXX right would otherwise be considered a timber resource property. ...

Gross resource profits includes income from the processing of ore from mineral resources. ... The definition of deposit in The Shorter Oxford English Dictionary (3rd. ed.) includes the following: "... something principal deposited, laid or thrown down; esp. matter precipitated from a fluid medium, or collected in one place by a natural process. ... Bethlehem Copper Corporation Ltd., 74 DTC 6502 (S.C.C.), Martland J. wrote for the court at page 6524 that "... the operation of a mine refers to the extraction of ore from the ore body. ...

Principal Issues: 1) Should the hedging gain be included in gross resource profits? ... In the Federal Court- Trial Division case of Cominco Ltd. (84 DTC 6535), the issue was whether income of a resource company should be included in "resource profits" for the purpose of calculating the resource allowance. ... Other comments As provided in our file # 2000-0036547, "the recapture provisions of the Act and Regulations are fundamentally adjustments to income of previous years and do not create, in the year of disposal of the asset, some new form or source of income". ...

27 June 2006 Internal T.I. 2006-0174191I7- Partnership Wind-Up and Resource Expenditures Unedited CRA Tags 98(3) 66(15) 66.1 Principal Issues: Taxation of partnership wind-up involving renounced resource expenditures. ... June 27, 2006 Vancouver Tax Service Office HEADQUARTERS John Lund Allan Nelson Complex Business Enquiries (613) 443-7253 2006-017419 Winding Up of Limited Partnership and Resource Expenditures Technical Interpretation We are writing in response to your March 1, 2006, facsimile transmission, which asked for our comments regarding the appropriate income tax treatment in a situation involving a limited partnership wind-up and the allocation of resource expenses to the former partners. ... We modified the hypothetical facts slightly to highlight what appear to be the two key aspects of your questions: the partnership wind-up and the flow through of the renounced resource expenses. ...

Robert Parsons stated: “ if the producer should choose to close out the forward sales contract earlier than it was required to do, by purchasing an equivalent amount of product, this action does not alter the characterization of the gain or loss on the forward sales contract as a hedging transaction. ... Timing of inclusion in gross resource Drofits- Regulation 1204 The positions described in #9226381 (October 2, 1992), in particular the discussion about resource profit recognition, have not changed. ... John Chan, Manager Resource Industries Section Resources, Partnerships and Trusts Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ...

20 January 2010 Internal T.I. 2009-0348571I7- Interest Rate Swaps and Resource Profits Principal Issues: Whether amounts paid by the taxpayer under various interest rate swap agreements need to be deducted in computing the taxpayer's resource profits Position: Yes Reasons: The payments were made in the course of carrying on its resource business and are not related to a source of income that does not include a resource activity January 20, 2010 XXXXXXXXXX Resources Industry Section Large File Case Manager T. ... The Queen 99 DTC 5669 [SCC] and Stewart v The Queen 2002 DTC 6969 "XXXXXXXXXX " However, we have been unable to identify any comments in either of these decisions that support the Representative's position. ... Resource Profits Subsection 1204(1.1) of the Regulations reads, in part, as follows:.... ...

In this case refund interest should not be included in gross resource profits. ... Legislation Adjusted resource profits is computed by reference to the definitions of "resource profits" and "gross resource profits" in subsections 1204(1.1) and 1204(1) of the Regulations, respectively. ... It is arguable that interest income on short term deposits, as well as interest on overpayment of taxes, would not be included in the narrower term 'income from the production and processing in Canada...of ore... ' used in paragraph 1204(1)(b)(ii) of the Regulations. ...

19 June 1990 Internal T.I. 74779 F- Non-capital Losses & RRSP Contributions Unedited CRA Tags 3(a), 3(c), 146(1) earned income, 146(5)   June 19, 1990 THUNDER BAY DISTRICT OFFICE HEAD OFFICE Appeals Division Resource Industries   Section   Frank S. ... Christy (613) 957-9768 19(1) File No. 7-4779 SUBJECT:  Renounced Resource Expenses creating Non-Capital Losses & RRSP Contributions Resource Expense Deduction This is in response to your memorandum dated February 26, 1990, concerning the above-mentioned topics. ... ChiefResource Industries SectionBilingual Service and Resource Industries DivisionRulings Directorate  ...