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“Mineral resource” is defined in subsection 248(1) of the Act as follows: “ mineral resource” means (a) a base or precious metal deposit, (b) a coal deposit, (c) a bituminous sands deposit or oil shale deposit, or (d) a mineral deposit in respect of which (i) the Minister of Natural Resources has certified that the principal mineral extracted is an industrial mineral contained in a non-bedded deposit, (ii) the principal mineral extracted is ammonite gemstone, calcium chloride, diamond, gypsum, halite, kaolin or sylvite, or (iii) the principal mineral extracted is silica that is extracted from sandstone or quartzite Since gold is a precious metal, the gold deposit on the Property qualifies as a “mineral resource” under paragraph (a) of that definition and no certification is required. ...

You also query whether the Ontario R&D Super Allowance is treated differently than the Nova Scotia R&D Tax Credit with respect to the Investment Tax Credit, including subsection 127(11.1) of the Act, and Scientific Research and Experimental Development ("SR & ED"), including paragraph 37(1)(d) of the Act. ...

Par conséquent, le montant maximum que peut contribuer ce contribuable à titre de prime à un REER correspond au moindre de 3 500 $ et de 20% du revenu gagné moins les cotisations versées à un régime de pensions et qui peuvent être déduites selon l'alinéa 8(1)m) de la Loi. ...

As a consequence of our view on the timing of the ABIL, we intend to inform 24(1) We would appreciate hearing from you as soon as possible on the   assessing/legislation issue so that we might finalize our reply to 24(1) 24(1) Director GeneralRulings DirectorateLegislative & Intergovernmental Affairs Branch ...

9 April 1992 External T.I. 9204255 F- Income Of Status Indian-Self Employed Unedited CRA Tags 81(1)(a), 9 19(1)     920425 Glen Thornley (613) 957-2101 April 9, 1992 Dear 19(1) Re:  Income of Status Indians This is in reply to your letter of January 2, 1992 addressed to the Ottawa District Taxation Office that was sent to us for reply. 19(1) Our Comments Status Indians are exempt from income taxes on employment income received from an employer situated on a reserve by virtue of the Indian Act and those Indians performing services on a reserve who are employed by employers situated off a reserve are entitled to a remission of any taxes paid on such employment income by virtue of the Indian Remission Order.  ...

It is also our view that the warrants issued by the corporation would not constitute "... a right to receive... shares" of the capital stock of the corporation for purposes of subsection 85(1) of the Act. ...

Enclosed for your perusal is a copy of the 1989 guide issued by Revenue Canada, Taxation entitled " Rental Income Tax Guide". ...

Your reasoning was that "... if the provisions of clause 37(7)(f)(iii)(B) of the Act were to apply to such a corporation, clause 37(7)(f)(iii)(A) of the Act would not serve any useful purpose for a corporation resident in Canada and exempt from tax under paragraph 149(1)(j) of the Act (underlined text added).  ...

Yours truly, for the DirectorBilingual Services & Resource Industries DivisionRuling Directorate ...

17 October 1990 External T.I. 9018865- Corporations associées- Années d'imposition se terminant a des dates différentes Unedited CRA Tags 129(6), 249(4) 24(1) 5-901886   M. ...