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(f) of the definition of CEE in ss. 66.1(6) and impact on the Guidelines As requested, we have updated the “Guidelines for determining the tax treatment of certain exploration expenses” that was issued in 2007 (the “ Guidelines ”) to reflect legislative changes to the income tax treatment of certain community consultation expenses and environmental study expenses incurred by mining companies at the exploration stage after February 2015. This updated version incorporates the recent legislative amendment to paragraph (f) of the definition of Canadian exploration expenses (“ CEE ”) in subsection 66.1(6) of the Income Tax Act introduced by the Budget Implementation Act, 2016, No. 1, S.C. 2016, c. 7. ... Yours truly, Fiona Harrison Manager Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch cc: Jane Stalker Industry Specialist Services – Resource Industry Section Coordinator Large Business Audit Division International and Large Business Directorate Guidelines for Determining the Tax Treatment of Certain Exploration Expenses Note: This table has been prepared to provide the guidelines that the Canada Revenue Agency will follow in determining whether environmental study expenses, community consultation expenses and feasibility study expenses that are incurred by mining companies at the exploration stage (i.e. for the purpose of determining the existence, location, extent or quality of a mineral resource in Canada, hereinafter referred to as the “purpose test”) will qualify as Canadian exploration expenses (“CEE”). ...

7 September 1989 Internal T.I. 73827 F- Clear the Paperwork Unedited CRA Tags 66.1(7)   September 7, 1989 To: Policy and Systems Branch From: Rulings Directorate Special Audits Division Resource Industries   Section R.S. ...

February 13, 2007 DAVE LARSEN HEADQUARTERS Appeals Division / Resource Officer James Atkinson CGA Sudbury Tax Centre / Tax Services Office (519) 457-4832 2006-021770 Paragraph 60.1(3)(b)- Retroactive Arrears This is in response to your e-mail of December 11, 2006 and the additional information submitted January 16, 2007 inquiring about the deeming provisions provided in subsection 60.1(3) of the Income Tax Act ("Act"). ... The Agreement acknowledged spousal support payments made in prior years, and calculated arrears as follows: Year: Obligation*: Paid: Arrears: XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX * There is no prior written agreement or order requiring these amounts to be paid. ...

5 December 1989 Internal T.I. 32679 F- Limited Partner At-risk Rules Unedited CRA Tags 96(2.2)(d), 248(a)(iii), 6205(1)(a)(ii), 6202   December 5, 1989 Review Committee Resource Industries   Section   Allan B. Nelson   957-8984   3-2679 SUBJECT: Limited Partner At-risk Rules Paragraph 96(2.2)(d) of the Act Purpose We are writing to request your direction concerning the possible application of paragraph 96(2.2)(d) of the Act in a fact situation on which we have been asked to provide an advance income tax ruling. ... The wording of the question responded to at the 1984 Conference was very broad, but if we view it in the same light as the above discussions, 24(1) 21(1)(b) Alternatives Based on the above information and that contained in our November 8 memo to the Review Committee we submit the following alternatives: 21(1)(b) Recommendation 21(1)(a) 21(1)(b) Section Chief Resource Industries SectionBilingual Services and Resource Industries DivisionRulings Directorate enclosures ...

In more detail, the facts are: 24(1) 3.      The vendor's representative,        19(1) 19(1)    is of the view that the proceeds of disposition on the sale of the  property for the purposes of section 116 of the Act include the consideration represented by the purchaser's assumption of the take-or-pay obligation, and that the deduction available to the vendor pursuant to subsection 20(24) of the Act may be deducted in the computation of the proceeds of disposition of the property in determining the taxes payable as described in paragraph 116(5.2)(a) of the Act. ... Acting DirectorBilingual Services & Resource Industries DivisionRulings Directorate Note to file                                     John Shaw re:  reply to Non-resident Taxation Division on inplications of take-or-pay contract being assumed for subsection 116(5.2) of the Act As this matter would ordinarily be dealt with by the Foreign Section of Rulings, I discussed it with Keith Harding of that Section on June 26, 1991, leaving Keith a copy of the proposed reply at his request for him to bring to his chief's attention. ...

On November 30, 1987, Company S sold all of its Canadian resource properties to Company E under circumstances whereby the successor rules in section 66.7 of the Act apply. 2.      ... Company S's taxable income for its taxation year ended October 31, 1988 was $100 million, solely by virtue of the negative cumulative Canadian development expense ("CCDE") balance resulting from the sale of the resource properties to Company E. 4.      ... Section ChiefResource Industries SectionBilingual Services and Resource Industries DivisionRulings Directorate ...

October 10, 2006 Jane Stalker HEADQUARTERS Coordinator, Natural Resources Income Tax Rulings Industry Specialist Services Directorate Technical Applications & Valuation Division Marc Edelson, LL.B. 112 Kent St., Room 1330 (613) 957-2123 Ottawa, Ontario K1A 0L5 2006-016905 Successor Pool Issues We are writing in reply to your memorandum of January 30, 2006, as subsequently amended on October 2, 2006, wherein you requested our views regarding various successor pool issues. ... Allocation of Income to Separate Resource Properties The entitlement to claim a successor pool deduction is based on having income that is reasonably attributable to production from a particular resource property. More particularly, as an example subsection 66.7(5) reads: 66.7(5) "... where... a corporation (... ...

F3039 F- CCA Class 28- Major Mine Expansion Unedited CRA Tags n/a   October 16, 1989 Ms C. ... Burnett/957-2078 Resource Industries Division   File No. F-3039 Class 28- Major Mine Expansion This is in response to the memorandum of June 12, 1989 prepared by A. ...

" of a property, other than a timber resource property, that is a timber limit or a right to cut timber from a limit;" 14A.       ... As to the intent of the legislation, the ''Explanatory Notes" to Bill C-49, given Royal Assent on March 13, 1975 commenting on paragraph 13(21)(d.1) state:       "This new provision defines "timber resource property".  ... Yours truly, DirectorBilingual Services & Resource Industries DivisionRulings Directorate ...

VI Canada US Treaty,   September 21, 1989 International Audits Division Specialty Rulings S. ... Harms   957-2109 Attention:  Clayton Davies   File No. 7-4067 Subject: Real Property:  Article XIII of the Canada-U.S. ... " The question thus arises whether, asbestos tailings constitute mineral deposits, sources or other natural resources.  ...