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30 October 1990 Internal T.I. 9027997 F- Flow-through Shares and Identical Properties Unedited CRA Tags 47(1), 53, 63.3(3), 66(15) flow-through share   October 30, 1990 Special Audits Division Head Office   Rulings Directorate E.H. Gauthier Resource Industries Director Section   Allan Nelson Attention: M. ... Our Position 1.     The FTS and NFTS noted in your memo to us would be identical properties to each other for the purposes of subsection 47(1) of the Act. 2.      ...

1993 Internal T.I. 9328657 F- Successor Rules Re Partnership and Change of Control Unedited CRA Tags 66.7(10)(j), 96(1)   October 7, 1993 Calgary District Office Resource Industries J. ... This position only applies to a situation wherein a successor corporation has acquired resource properties under circumstances such that the section 66.7 successor rules (the "Successor Rules") apply and these resource properties are subsequently transferred to a partnership of which the successor corporation is a partner. ... It is the Department's position that an interest in a partnership, the underlying property of which consists of Canadian resource property, is not a Canadian resource property. ...

On audit of the JEC, some of these expenditures may be reclassified from Canadian Exploration Expenses (CEE) to Canadian Development Expenses (CDE), or vice versa. 1)     Should the shareholder corporation's tax pools be amended to reclassify the renounced expenditures? 2)     What is the proper taxation year in which the pools are to be revised TAX IMPLICATIONS 1)     To preclude the JEC from subsequently renouncing the reclassified expenditures of claiming them again as a deduction (double claim). 2)     To ensure that the reclassified amounts are included in the correct resource pools of a shareholder corporation and in the proper year. DEPARTMENT'S POLICY The Department is prepared to adjust the resource pools of a shareholder corporation in the year(s) the reclassifications were made to the JEC.  ...

Even more resources would be required to be used if a taxpayer has complex operations, such as foreign income sources. ... However, since the Minister has limited resources available to administer the tax system, there is a need to finalize the assessment process at some point. ... As stated in paragraph 49, the implied exception rule “was described in James Richardson & Sons, Ltd. v. ...

May 31, 2001 Calgary Tax Services Office HEADQUARTERS Oil & Gas Specialists Karen Power, CA Industry Specialist Services (613) 957-8953 Attention: Zul Ladak & Bharat Patel 2000-006233 Resource Allowance- Prepaid Forward Sales We are replying to your letter of December 19, 2000, in which you requested our opinion on whether payments received by XXXXXXXXXX under a Master Forward Sales Agreement ("Master") and Form of Purchase Agreement ("Purchase") should be bifurcated into two components, namely a sale and a loan. ... The issue of whether payments were an acquisition of a resource property or in substance a loan was considered in the case of Alberta and Southern Gas Co. ... The resulting income inclusion would increase resource profits for purposes of calculating XXXXXXXXXX resource allowance. ...

Gauthier Resource Industries Section Director John Chan   952-9019 Bob Neville   Specialized Industries Section File No. 7-4629 Subject: Request for Technical Interpretation Classification of Pipeline Schedule II of the Income Tax Regulations (the "Regulations") We are writing in reply to your request for an interpretation regarding the proper classification of a pipeline and related gas gathering equipment for capital cost allowance ("CCA") purposes. ... You then ask what the proper CCA classification of the system would be if the System is used for gathering and transmission of natural gas to (a)     a main transmission line operated by an unrelated public utility, (b)     a gas plant owned by a third party, and (c)     a straddle plant owned by a third party. ... DirectorBilingual Services and Resource Industries DivisionRulings Directorate ...

Fisc. for Acting Director Ontario Corporate Tax Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch Cc: Steve Goggin, Team Leader- ECA, Revenue Collection Division, Edmonton TSO Shirley Greening, Communications Resource Officer, Individuals & Benefit Services, Winnipeg TSO Janine Grace, Technical Advisor, Individual Returns & Compliance Division, Winnipeg TSO ...

A detailed description of switchgrass production and its different uses can be found on the website of the Resource Efficient Agricultural Production (REAP) organization at www.reap-canada.com. The website suggests that the information therein was co-produced or sponsored by Ontario Ministry of Agriculture, Food & Rural Affairs, the Natural Resources Canada, Canadian Farm Business Management Council and the Collège d'Alfred/University of Guelf. ...

24 March 1993 Internal T.I. 9300097 F- CCA Mining and Electroic Data Process/Auto Equipment Unedited CRA Tags ITR 1100, Class 10   Edmonton District Office Resource Industries Section Attention:  Marlene White  Large Case File Manager XXXXXXXXXX Class 10 Misclassifications This is in reply to your request dated January 5, 1993 concerning the classification for Capital Cost Allowance purposes of certain automotive and electronic data processing equipment related to XXXXXXXXXX. ... A/Chief Resource Industries Section Manufacturing Industries, Partnerships and Trusts DivisionRulings Directorate ...

Power   FILE 903359             SUBJECT:     Offshore Activities Article Canada-Netherlands Income Tax Convention We are writing in reply to your memorandum dated November 22, 1990, in which you requested our comments concerning the offshore activities article in the above-noted treaties. ... 4.     What are to be considered activities that would be carried on in Canada in connection with the exploration or exploitation of the seabed and subsoil and their natural resources ("in connection with the offshore resources")? ... 2.      What would be considered to be "offshore" for the purposes of this Article? ...