The Queen v. Gulf Canada Ltd., 92 DTC 6123,  1 CTC 183 (FCA)
Scientific research expenditures of the taxpayer were related to its long term objectives and not to the actual physical production of mineral resources and, accordingly, were not deductible in computing its production profits under s. 124.1. The word "production" in s. 124.1(1)(b)(i) was used in its "narrow sense of extraction from the ground" (p. 6126).
|Locations of other summaries||Wordcount|
|Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (a)||no connection betweeen lease payments and exploration||131|
|Tax Topics - Statutory Interpretation - Comparison of Provisions||presumption that word's meaning is consistent||44|