Section 66

Table of Contents

Subsection 66(4) - Foreign exploration and development expenses

Administrative Policy

November 1991 Memorandum (Tax Window, No. 12, p. 14, ¶1563)

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88 CPTJ - Q.15

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Subsection 66(6)

Cases

Wardean Drilling Co. Ltd. v. M.N.R., 78 DTC 6202, [1978] CTC 270 (FCTD)

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Subsection 66(9)

Administrative Policy

93 C.P.T.J. - Q.26

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Subsection 66(10)

Articles

Sanderson, "Joint Exploration Corporations - An Overview", 1994 Canadian Petroleum Tax Journal, Vol. 7, No. 1, p. 53.

Subsection 66(10.1)

Administrative Policy

31 May 1994 External T.I. 5-940585 -

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93 C.P.T.J. - Q.35

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93 C.P.T.J. - Q.34

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93 C.P.T.J. - Q.30

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92 C.R. - Q.15

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 66 - Subsection 66(12.6) 33

September 1991 T.I. (Tax Window, No. 9, p. 1, ¶1461)

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90 C.P.T.J. - Q.9

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88 C.P.T.J. - Q.6

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Subsection 66(10.2)

Administrative Policy

93 C.P.T.J - Q. 33

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Subsection 66(11.4) - Change of control

Administrative Policy

S3-F8-C1 - Principal-business Corporations in the Resource Industries

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Subsection 66(12.1) - Limitations of Canadian exploration and development expenses

Administrative Policy

93 C.R. - Q. 26, Q. 27

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12 June 1992 Memorandum (Tax Window, No. 21, p. 10, ¶2023)

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92 CPTJ - Q.16

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5 April 1991 T.I. (Tax Window, No. 3, p. 6, ¶1268)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 54 - Proceeds of Disposition 64

90 C.P.T.J. - Q.2

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90 C.P.T.J. - Q.3

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88 C.P.T.J. - Q.11

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88 C.R. - Q.21

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Subsection 66(12.5) - Unitized oil or gas field in Canada

Administrative Policy

92 C.P.T.J. - Q.1

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Subsection 66(12.6) - Canadian exploration expenses to flow-through shareholder

Cases

Tusk Exploration Ltd. v. Canada, 2018 FCA 121

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 211.91 - Subsection 211.91(1) Part XII.6 tax was payable on CEE purportedly renounced on a look-back basis to NAL shareholders 497
Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) potential for double taxation under the ITA of NAL transactions 295
Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(a) double taxation can result from non-arm’s length transactions such as under s. 69(1) 287

See Also

Hamilton v. The Queen, 97 DTC 787 (TCC)

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Administrative Policy

11 October 2013 Roundtable, 2013-0495271C6 F - Flow-through shares and death

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 66 - Subsection 66(12.66) lookback unavailable where taxpayer was deceased on December 31 of look-back year 178

9 August 2012 External T.I. 2012-0455341E5 - CEE/CDE incurred by Subsidiary

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92 C.R. - Q.15

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 66 - Subsection 66(10.1) 33

14 September 89 T.I. (February 1990 Access Letter, ¶1108)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Effective Date 155

Articles

Gregory M. Johnson, Wesley R. Novotny, "An Update on Flow-through Shares in the Energy Sector", 2016 Conference Report (Canadian Tax Foundation),12:1-39

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Ronald Richler, "Creststreet Income Fund Uses Flow-Through Shares", Corporate Finance, Vol. XI, No. 4, 2004, p. 1124.

Paragraph 66(12.6)(a)

Articles

Emmanuel Sala, "Flow-Through Share Financing: Recent Developments, Traps and Tips", 2015 CTF Annual Conference paper

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Subsection 66(12.602) - Idem [Amalgamations and mergers]

Administrative Policy

9 January 2004 Memorandum

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Subsection 66(12.66) - Expenses in the first 60 days of year

Administrative Policy

11 October 2013 Roundtable, 2013-0495271C6 F - Flow-through shares and death

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 66 - Subsection 66(12.6) renunciation must take effect before the death of the deceased and is unavailable to estate 194

28 January 1994 External T.I. 7-940185 -

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90 C.P.T.J. - Q.13

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88 C.R. - Q.23

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Subsection 66(12.69) - Filing re partners

Administrative Policy

87 C.R. - Q.30

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Subsection 66(12.7) - Filing re renunciation

Administrative Policy

87 C.R. - Q.29

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87 C.R. - Q.31

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Subsection 66(12.71) - Restriction on renunciation

Administrative Policy

2016 Ruling 2015-0614081R3 - Flow through shares - farm-out agreement

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (f) exploration under farm-in not integrated with existing mine workings 434

93 C.R. - Q. 24

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Subsection 66(12.73) - Reductions in renunciations

See Also

Fagan v. The Queen, 2012 DTC 1139 [at 3217], 2011 TCC 523

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Administrative Policy

88 C.R. - Q.66

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Articles

Gregory M. Johnson, Wesley R. Novotny, "An Update on Flow-through Shares in the Energy Sector", 2016 Conference Report (Canadian Tax Foundation),12:1-39

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Subsection 66(14.5) - Penalty for late designation

Administrative Policy

89 C.P.T.J. - Q25

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Subsection 66(15) - Definitions

Canadian Resource Property

Cases

Markin v. The Queen, 96 DTC 6483 (FCTD)

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Alberta and Southern Gas Co. Ltd. v. The Queen, 76 DTC 6362, [1976] CTC 639 (FCTD), aff'd 77 DTC 5244 [1977] CTC 388 (FCA), aff'd 78 DTC 6566, [1978] CTC 780, [1979] 1 S.C.R. 36

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See Also

Alberta Energy Co. Ltd. v. The Queen, 95 DTC 220 (TCC), aff'd 98 DTC 6007 (FCA)

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Administrative Policy

13 March 2013 Internal T.I. 2013-0480511I7 F - Canadian resource property

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7 January 2013 External T.I. 2012-0460791E5 - Qualified Farm Property & Oil Reserves

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2 December 2003 External T.I. 2003-004860A - CRP - Rentals and Royalties

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Income Tax Technical News, No. 10, 11 July 1997: "Net Profits Interests and Proposed Section 18.1"

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21 August 1995 External T.I. 5-951493 -

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94 CPTJ - Q. 21 (941034)

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88 CPTJ - Q.16

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Articles

Randy S. Morphy, Kim Maguire, "An Update on the Taxation of Farm-outs", Resource Sector Taxation, Vol. IX, No. 3, 2013, p. 661.

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Randy S. Morphy, Richard Eisenhorn, "The Taxation of Royalties Excluded from the Resource Property Regime", Resource Sector Taxation, Vol. IX, No. 1, 2012, p.618

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Allgood, "Athabasca Oil Sands Trust: Tax Implications of Royalty Trust", Corporate Finance, Vol. V, No. 1, p. 348: Includes reference to a ruling that a net royalty in the production of synthetic crude oil was a Canadian resource property.

Fryers, "'Net Serve! One to Come!' (The Net Profits Interest in the Oil and Gas Industry - An In-Depth Analysis)", 1988 Canadian Petroleum Tax Journal, Spring 1988, p. 121: It is concluded that a net profits interest is a Canadian resource property by virtue of s. 66(15)(c)(iv).

Flow-Through Share

Cases

Canada v. JES Investments Ltd., 2007 DTC 5608, 2007 FCA 337

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Administrative Policy

5 September 2014 External T.I. 2014-0534941E5 - Flow-through share ss 66(15) of the Income Tax Act

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28 November 2010 CTF Annual Roundtable, 2010-0384341C6 - Flow-through Shares

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6 September 1994 Memorandum 941986 and 942090 (C.T.O. "Are Special Warrants Flow-through Shares?)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 49 - Subsection 49(3) 49

6 December 1989 T.I. (May 1990 Access Letter, ¶1218)

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Articles

Gregory M. Johnson, Wesley R. Novotny, "An Update on Flow-through Shares in the Energy Sector", 2016 Conference Report (Canadian Tax Foundation),12:1-39

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Emmanuel Sala, "Flow-Through Share Financing: Recent Developments, Traps and Tips", 2015 CTF Annual Conference paper

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Foreign Exploration and Development Expenses

Administrative Policy

90 C.P.T.J. - Q.36

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Joint Exploration Corporation

Administrative Policy

23 June 1992 T.I. 921868 (January - February 1993 Access Letter, p. 20, ¶C56-211)

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5 September 1991 T.I. (Tax Window, No. 9, p. 19, ¶1446)

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Original Owner

Administrative Policy

94 C.P.T.J. - Q. 10

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Principal-Business Corporation

Cases

Wardean Drilling Co. Ltd. v. M.N.R., 78 DTC 6202, [1978] CTC 270 (FCTD)

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Alberta and Southern Gas Co. Ltd. v. The Queen, 76 DTC 6362, [1976] CTC 639 (FCTD), aff'd 77 DTC 5244 [1977] CTC 388 (FCA), aff'd 78 DTC 6566, [1978] CTC 780, [1979] 1 S.C.R. 36

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M.W.A. Gas and Oil Ltd. v. MNR, 74 DTC 6123, [1974] CTC 140 (FCTD)

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Sogemines Development Co. Ltd. v. MNR, 72 DTC 6254 (FCTD)

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Minister of National Revenue v. Consolidated Mogul Mines Limited, 68 DTC 5284, [1968] CTC 429, [1969] S.C.R. 54

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Words and Phrases
principal business

See Also

Ethyl Corp. of Canada Ltd. v. The Queen, 80 DTC 6194, [1980] CTC 198 (FCA)

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Words and Phrases
petroleum products

Administrative Policy

S3-F8-C1 - Principal-business Corporations in the Resource Industries

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11 July 1989 T.I. (Dec. 89 Access Letter, ¶1046)

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89 C.P.T.J. - Q10

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88 CPTJ - Q.8

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86 C.R. - Q.6

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Production

Administrative Policy

10 February 1999 T.I. 982685

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Paragraph 66(15)(i)

Administrative Policy

93 C.P.T.J. - Q.31

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89 C.P.T.J. - Q.3

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