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24 October 1990 Internal T.I. 9029017 F- Non-resident Information Package Unedited CRA Tags 237(1)   October 24, 1990 Non-Resident Taxation Division Resource Industries K. ... This may require some repetitions of information, but would not require the reader to read the entire booklet item by item to find out what must be done. 3.     21(1)(a) 4.      ... Acting/DirectorBilingual Services and Resource Industries DivisionRulings Directorate ...

19 October 1990 Internal T.I. 9027557 F- Deductibility of Foreign Exploration and Development Expenses Unedited CRA Tags n/a   October 19, 1990 Audit Programs Directorate Resource Industries Special Audits Division Section E.H. ... Chisholm 7-902755 SUBJECT:  Oil & Gas Issue Report #04 Foreign Exploration and Development Expenses ("FEDE") As requested in your memorandum dated September 26, 1990, we confirm that the letters issued by the Rulings Directorate on August 31, 1987 and August 27, 1990 pertaining to the deductibility of FEDE reflect the Directorate's current position with respect thereto. We are also sending copies of correspondence issued by the Rulings Directorate on June 23, 1987, September 4, 1985 and October 11, 1984 which further support the audit policy on the deductibility of FEDE in your Oil and Gas Issue Report # O&G 04. ...

Reasons: QR is defined in subsection 125.7(1) of the Act to mean “the inflow of cash, receivables or other consideration arising in the course of the ordinary activities of the eligible entity — generally from the sale of goods, the rendering of services and the use by others of resources of the eligible entity — in Canada in the particular period”, subject to certain exclusions or exceptions. ... However, that inflow constituted a reimbursement (or a liability if the amount is received as an advance), rather than an inflow from the sale of goods, the rendering of services, or the use by others of resources of the eligible entity. ... Our Comments As provided by subsection 125.7(1) of the Act, qualifying revenue of an eligible entity for a prior reference period or a current reference period, means the inflow of cash, receivables or other consideration arising in the course of the ordinary activities of the eligible entity — generally from the sale of goods, the rendering of services and the use by others of resources of the eligible entity — in Canada in the particular period, subject to certain exceptions and exclusions. ...

Principal Issues: Whether AGR-1 information slips need to be issued in respect of two farm programs (Matinee Racetrack Assistance Program and Agriculture and Environment Resource Conservation Program) Position: Yes Reasons: They are farm support payments described in Regulation 234(2) November 5, 1999 Charlottetown Tax Services Office HEADQUARTERS Client Services Directorate M. ... Agriculture and Environmental Resource Conservation Program ("Program B") The purpose of Program B is to assist P.E.I. farmers to produce high quality food products from sustainable on-farm production systems. ... John Oulton Section Chief Business, Property & Employment Section III Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch?? ...

29 March 1990 Internal T.I. 00159 F- Preproduction Revenue Unedited CRA Tags 59(3.3)(a), 59(3.3)(f) Special Audits Division Resource Industries E.H. ... White   (613) 957-8585 R. Neville   File No. 0-0159 Re: Preproduction Revenue 21(1)(b)  the Department is presently handling preproduction revenue from conventional and oil sands mining and how it pertains to earned depletion, mining exploration depletion and the recapture of earned depletion and mining exploration depletion pursuant to paragraphs 59(3.3)(a) and (f). 21(1)(b) If you require further information please contact the writer. Director Bilingual Services and Resource Industries DivisionRulings Directorate ...

Paragraph 15      With respect to timber properties, this term is too vague and could be construed as including such timber properties as timber limits and cutting rights which may not be timber resource properties for purposes of the Act- see paragraph 13(21)(d.1) for the definition of timber resource properties.  We suggest the term "timber resource property" be used instead as this term is specifically contemplated by the legislation.        ... This would be more in keeping with the text of the legislation.      We suggest that the defined term Canadian resource property be used instead of the words "Canadian mining, oil" at paragraph 15(d) as this would be more explicit to the reader. 4.      ...

19 February 1991 Internal T.I. 910337 F- CCA Class 34 Unedited CRA Tags ITR 1100(24), ITR 1100(25), ITR 1100(26), ITR 1100(27) Dear Sirs: Re: Class 34 As requested in your telephone conversation, 19(1)  Dath) we are enclosing the following regarding capital cost allowance available under class 34 of the Income Tax Regulations (the Regulations): 1.     Class 34 of the Regulations. 2.     Subsections 1100(24), (25), (26), & (27) of the Regulations. 3.     Class 34 Pamphlet published by Energy, Mines and Resources Canada. We trust the enclosures will be of assistance to you. ...

In a News Release on February 21, 1990, the Honourable Jake Epp, Minister of Energy, Mines and Resources announced the immediate termination of CEIP, subject to certain grandfathering rules which were provided in a News Release on March 9, 1990. 3.      ... "Eligible exploration expense" in relation to a mineral resource and hydrocarbons is defined in subsections 5(1) and (2) of the CEIP Regulations. 5.      ... Dan MacDonald, Energy Mines and Resources with whom the above was informally discussed. ...

In order to complete our consideration of this request we require the following: 1.     A description and/or documentation of the Institute's activities or proposed activities, including a description of the staff and physical resources of the Institute. 2.      ... This would include documents such as the charter, bylaws, trust declaration, information brochures, etc. 3.      ...

Section 255 of the Canadian Income Tax Act (the "Act") provides that "Canada" is hereby declared to include and to have always included (a)     the sea bed and subsoil of the submarine areas adjacent to the coasts of Canada in respect of which the Government of Canada or of a province grants a right, license or privilege to explore for, drill for or take any minerals petroleum, natural gas or any related hydocarbons: and (b)     the seas and airspace above the submarine areas referred to in paragraph (a) in respect of any activities carried on in connection with the exploration for or exploitation of the minerals, petroleum, natural gas or hydrocarbons referred to in that paragraph. The Income Tax Conventions Interpretation Act defines Canada as follows; "Canada" means the territory of Canada, and includes (a)     every area beyond the territorial seas of Canada that, in accordance with international law and laws of Canada, is an area in respect of which Canada may exercise rights with respect to the sea bed and subsoil and their natural resources, and (b)     the seas and airspace above every area described in paragraph (a). ...