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Position: The payments represent proceeds of disposition of a "timber resource property" to the contractors. ... The amount received by FBL of $ 800,000 bore no relation to the value of the foregone contracts of $ 12 million. ... Yours truly, for Director Reorganizations and Resources Division Income Tax Rulings Directorate ...

I3317 F- Payments as Inducement or Reimbursement- Quebec Tax Credit for Losses Unedited CRA Tags 12(1)(x)   October 16, 1989 Ms C. ... Burnett/957-2078 Resource Industries Division   File No. I-3317 Quebec Tax Credit for Losses and Paragraph 12(1)(x) of the Income Tax Act Enclosed is a copy of a letter we received from the Department of Finance concerning the above subject. ...

24 September 1993 Internal T.I. 9327027 F- Investment Tax Credit- Logging Trucks Unedited CRA Tags 127(9) investment tax credit, 127(9) qualified property, ITR 4600(2)   Halifax District Office Resource Industries Audit Division Section Business Enquiries Attention:  Kevin McGuigan  Investment Tax Credit on Logging Trucks This is in reply to your enquiry dated September 21, 1993 wherein you ask for confirmation that certain trucks used by a contractor for the purpose of transporting cut logs from the cut area to the mill are considered to qualify for the purpose of the Investment Tax Credit. ...

"resource-based industry" means an industry that uses as a principal material a material (a)     the original location of which is not the consequence of human design, and (b)     that is in or close to its natural state. ... However, we have to determine whether the Plant Operation is an initial processing operation in a resource-based industry. 10.      Pursuant to the above-noted definition of the expression "resource-based industry", the natural gas processing industry is a resource-based industry. 11.      ...

ACC8367 F- Flow-through Shares Audit Program Position Papers Unedited CRA Tags n/a                                                               August 22, 1987 Special Audits Division             Resource Industries                                                Section E.H. ... DirectorBilingual Services and Resource  Industries DivisionRulings Directorate Position Paper # 1- Dual purpose Canadian Exploration Expenses                       (CEE) Subparagraph 66.1(6)(a)(iii) and(iii.1) With respect to the issue of dual purpose CEE {which is an expense incurred for the purpose of both subparagraphs 66.1(6)(a)(iii) and (iii.1)}, we agree with your first position that a taxpayer may choose to classify such an expense incurred principally for the purpose of 66.1(6)(a)(iii.1) and a (iii) expense where a secondary purpose exists. ... Position Paper # 5- Renunciation of resource expenses incurred  prior to entering in an agreement Paragraph 66(15)(d.1) and subsections       66(12.6), 66(12.62) and 66(12.64). ...

Gauthier                             Resource Industries Section Director                                Allan Nelson                                         (613) 957-2745 L.M. ... If such was the case and ECE treatment was denied, then the damage payments would not be deductible at all by the PBC.       ... Acting/DirectorBilingual Services & Resource Industries DivisionRuling Directorate   7-903236   Allan Nelson   Resource Industries Section General The basic question posed to us by Special Audits was what would be the proper tax treatment for damages plus interest payments made by a corporation ("PBC") to partners of a partnership which invested in flow-through shares ("FTS") issued by the PBC. 24(1) Issue #1 Would different tax treatment be given if the damages were paid as 1)     an out of court settlement, 2)     after the PBC is sued by the partners but prior to any court order; or 3)     pursuant to a court order? ...

13 July 1992 Internal T.I. 9119437 F- CCA Classification- Refinging Equipment Unedited CRA Tags ITA 1100 sch II July 13, 1992 Audit Technical Support Division Resource Industries     Section A/Director B. ...

Issues 1.     Is a surface right considered to be a Canadian resource property pursuant to paragraph 66(15)(c)? ... 3.     Is a surface rights rental on account of capital or current expense? ... As discussed in 1 above, a surface right is not a Canadian resource property.  ...

29 August 1989 Internal T.I. 58509 F- Foreign Exchange Loss, Whether Cost of Property Disposition Unedited CRA Tags n/a   August 29, 1989 To: Bilingual Services and Resource Industries Resource Industries Division Section   John Shaw Carole Gouin-Toussaint 957-8968 Director   File No. 5-8509 Subject: 24(1) This is briefing memorandum for our meeting to be held August 30, 1989 with the representatives of 24(1) Issue 21(1)(b) and 24(1) Facts 24(1) Taxpayer's Arguments 24(1) We, at least for the moment, concede that the prepayment penalty is an expense made or incurred for the purpose of making the disposition, but assert that the foreign exchange loss is not, as it is part of the repayment of the loan, which repayment itself, may hardly be considered a cost of disposition of property. ... Demers, 86 DTC 6411, at page 6413, where he stated:      "Further of a payment which would otherwise be an outlay within the meaning of a provision results in the taxpayer acquiring property with a value equal to that of the payment, it would be contrary to common sense to treat it as an outlay made "for the purpose of making the disposition".  ... " 21(1)(b) 24(1)  decisions in Olympia Floor & Wall Tile (Quebec) Ltée. 70 DTC 6085 and Impenco Ltd.  ...

Hoard Rulings Directorate Chief of Audit Resource Industries Section   Allan B. ... Our response to your query will be based on the following assumptions: 1.      ... For a more detailed discussion thereof, reference is made to the Ruling: (i) (ii) (iii)      24(1) (iv) (v) Rulings' Opinion Subsection 55(2) of the Act will be applicable in the above described instance. ...