Subsection 66(12.67)
Paragraph 66(12.67)(a)
Administrative Policy
2023 Ruling 2023-0961681R3 - CEE Incurred by a Non-resident
A Canadian exploration company (the Company) wholly-owned by a non-resident company (Company B) whose shares are listed, will incur exploration...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (f) | CEE incurred to expand the resource in order to potentially restart a mine | 429 |
| Tax Topics - Income Tax Act - Section 66 - Subsection 66(12.71) | renunciation by non-resident parent issuing flow-through shares of its CEE and renounced CEE of its Canadian sub re a mine restart project | 260 |
Subsection 66(4) - Foreign exploration and development expenses
Administrative Policy
November 1991 Memorandum (Tax Window, No. 12, p. 14, ¶1563)
Discussion of determination of numerical limit on the amount of the deduction.
88 CPTJ - Q.15
In light of Oceanspan, a U.S. citizen who has invested $1 million in U.S. oil and gas drilling expenses has not incurred any FEDE for purposes of...
Subsection 66(6)
Cases
Wardean Drilling Co. Ltd. v. M.N.R., 78 DTC 6202, [1978] CTC 270 (FCTD)
There was no requirement in s. 83A(8a) of the pre-1972 Act that the acquisition of property entail the acquisition of a business undertaking...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Evidence | 27 | |
| Tax Topics - Income Tax Act - Section 66 - Subsection 66(15) - Principal-Business Corporation | 65 |
Subsection 66(9)
Administrative Policy
93 C.P.T.J. - Q.26
Where a well, originally drilled in 1988, is re-entered in 1993 and drilling completed to a deeper zone resulting in the discovery of a new pool,...
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. 9405855 - RENUNCIATION BY JEC OF INTEREST CAPITALIZED TO CEE
Interest paid by a JEC on an interest-bearing loan received from a shareholder corporation in respect of which the JEC has elected under s. 21(2)...
93 C.P.T.J. - Q.35
Re effective date of a renouncement.
93 C.P.T.J. - Q.34
Re consequences of an excess renouncement.
93 C.P.T.J. - Q.30
A shareholder corporation need not be a shareholder of the JEC on the date renouncements were made, although it must have been a shareholder of...
92 C.R. - Q.15
CEE that has been renounced to a shareholder corporation by a JEC cannot then be renounced by the shareholder corporation to a third party under...
| 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)
Where a corporation whose wholly-owned subsidiary previously has incurred CEE causes the subsidiary to renounce the CEE in its favour and it, in...
90 C.P.T.J. - Q.9
Because s. 66(10.1)(c) deems a shareholder corporation to have incurred expenses only for purposes of the CEE and cumulative CEE definitions, a...
88 C.P.T.J. - Q.6
A JEC is entitled to renounce up to the full amount of its CEE irrespective of the fact that the JEC may have income in a particular year against...
Subsection 66(10.2)
Administrative Policy
93 C.P.T.J - Q. 33
Where during the year while Corporation A is a shareholder, the JEC incurs $1 million of CDE and in December of that year, the JEC sells all its...
Subsection 66(11.4) - Change of control
Administrative Policy
S3-F8-C1 - Principal-business Corporations in the Resource Industries
1.23 Subsection 66(11.4) is a deeming rule which applies if:
- a taxpayer is subject to a loss restriction event as defined in subsection...
Subsection 66(12.1) - Limitations of Canadian exploration and development expenses
Administrative Policy
93 C.R. - Q. 26, Q. 27
Discussion of RC position on widespread farm-outs, and on typical farm-outs in the mining industry.
12 June 1992 Memorandum (Tax Window, No. 21, p. 10, ¶2023)
General discussion.
92 CPTJ - Q.16
Detailed discussion of RC's policies on farmouts.
5 April 1991 T.I. (Tax Window, No. 3, p. 6, ¶1268)
Unde a widespread farm-out RC will consider the value of the non-contiguous property received by the farmee to be a reimbursement to the farmee...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 54 - Proceeds of Disposition | 66 |
90 C.P.T.J. - Q.2
RC will consider denying its farm-in treatment available under IT-125R3, para. 11 and applying ss.66(12.1)(a) and (b) where a farmee earns an...
90 C.P.T.J. - Q.3
Consequences of a farmee incurring CEE to earn an interest in a farmor's non-producing resource property where the farmee also receives an...
88 C.P.T.J. - Q.11
ss.66(12.1)(a) or (b) will be applicable under a farm-in where there is production from the acreage in which an interest is being earned.
88 C.R. - Q.21
Where CEE is incurred by a partnership, that expense is also incurred by the partner to which it is allocated.
Subsection 66(12.5) - Unitized oil or gas field in Canada
Administrative Policy
92 C.P.T.J. - Q.1
Re treatment of amounts received by a taxpayer under a unitization agreement in excess of the amounts actually expended by it.
Subsection 66(12.6) - Canadian exploration expenses to flow-through shareholder
Cases
Tusk Exploration Ltd. v. Canada, 2018 FCA 121
In the course of a general discussion, Webb JA stated (at para. 5):
Although subsection 66(12.6) of the ITA only refers to a “corporation”,...
| 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 | 515 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) | potential for double taxation under the ITA of NAL transactions | 307 |
| 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) | 301 |
See Also
Hamilton v. The Queen, 97 DTC 787, [1997] 1 CTC 2446 (TCC)
The payment of licence fees of a resource company by the taxpayer on the basis that the corporation would issue flow-through shares to him to...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss | 56 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(m) | 90 |
Administrative Policy
11 October 2013 Roundtable, 2013-0495271C6 F - Flow-through shares and death
An individual who acquired flow-through shares of a principal-business corporation (PBC) on February 1, 2013, entered into a flow-through share...
| 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 | 199 |
9 August 2012 External T.I. 2012-0455341E5 - CEE/CDE incurred by Subsidiary
Whee a subsidiary principal business corporation issues flow-through shares to its parent (also a principal business corporation) and uses the...
92 C.R. - Q.15
CEE that has been renounced to a shareholder corporation by a JEC cannot then be renounced by the shareholder corporation to a third party under...
| 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)
ss.16(12.6), (12.62) and (12.64), when they refer to "agreement" are reiterating the requirement in s. 66(15)(d.1) that the agreement be legally...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Effective Date | 165 |
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
No tracing and aggregation of CEE before flow-through share issuance (pp. 12:8)
The PBC is not required to trace the FTS subscription proceeds to...
Ronald Richler, "Creststreet Income Fund Uses Flow-Through Shares", Corporate Finance, Vol. XI, No. 4, 2004, p. 1124.
Paragraph 66(12.6)(a)
Administrative Policy
21 March 2006 External T.I. 2005-0158451E5 F - Québec Mining Duties Act - Credit for Losses
S. 32 of the Quebec Mining Duties Act (MDA) provided a credit to an operator equal generally to an amount not exceeding 12% of the lesser of (i)...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Cumulative Canadian exploration expense - Element J | credit under the Quebec Mining Duties Act based on exploration and development losses of operator was not “assistance" under J | 207 |
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x.2) | credit under the Quebec Mining Duties Act based on exploration and development losses of operator was not includible under s. 12(1)(x.2) | 208 |
Articles
Emmanuel Sala, "Flow-Through Share Financing: Recent Developments, Traps and Tips", 2015 CTF Annual Conference paper
Whether reduction for Quebec resource credit (pp. 10:24-25)
A problem arises when mining projects located in the province of Quebec are financed...
Subsection 66(12.602) - Idem [Amalgamations and mergers]
Administrative Policy
9 January 2004 Memorandum
A principal business corporation would not be prohibited from renouncing $2 million of specified CDE in a particular year comprising $1 million of...
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
An individual who acquired flow-through shares of a principal-business corporation (PBC) on February 1, 2013, entered into a flow-through share...
| 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 | 211 |
13 December 2004 External T.I. 2004-0094991E5 F - Look-Back Rule: Flow-Through Shares
On December 1 of Year 1, Investors subscribed $1,100 for 1000 units of an issuer (“Newco”) each consisting of a Class B common share...
28 January 1994 Internal T.I. 9401856 - 60 DAY RULE
Because the definition of "flow-through share" requires that CEE must be incurred during the period commencing with the day of the agreement and...
90 C.P.T.J. - Q.13
Discussion of application of rule where a well is abandoned within 90 days after the end of the year.
88 C.R. - Q.23
Description of trust account procedure for meeting the requirement that the consideration be paid before the end of the year.
Subsection 66(12.69) - Filing re partners
Administrative Policy
87 C.R. - Q.30
Revenue Canada will not process an income tax return where form T101A or T102 supplementary does not have an identification number.
Subsection 66(12.7) - Filing re renunciation
Administrative Policy
87 C.R. - Q.29
Discussion of "effective date of renunciation" referred to on form T101.
87 C.R. - Q.31
The renounced expenses do not necessarily have to relate to the property identified on form T101.
Subsection 66(12.71) - Restriction on renunciation
Administrative Policy
2023 Ruling 2023-0961681R3 - CEE Incurred by a Non-resident
A Canadian exploration company (the Company) wholly-owned by a non-resident company (Company B) whose shares are listed, determined that its mine...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (f) | CEE incurred to expand the resource in order to potentially restart a mine | 429 |
| Tax Topics - Income Tax Act - Section 66 - Subsection 66(12.67) - Paragraph 66(12.67)(a) | renunciation by Cdn sub to NR parent of CEE which it in turn renounces on FTS issued by it | 237 |
2016 Ruling 2015-0614081R3 - Flow through shares - farm-out agreement
Background
Bco, a U.S. public company, also is a principal-business corporation as substantially all of its assets are shares and debt of related...
| 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 | 481 |
93 C.R. - Q. 24
The fact that the CEE deduction to which a principal business corporation would otherwise be entitled is limited for a particular year, under s....
Subsection 66(12.73) - Reductions in renunciations
See Also
Wallster v. The King, 2022 TCC 124
The taxpayer was renounced Canadian exploration expense (CEE) by an issuer (Quattro) that the Minister subsequently determined had substantially...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(b) - Subparagraph 152(4)(b)(v) | the failure of an issuer to comply with CRA’s demand to allocate its over-renunciation of CEE precluded extending the normal reassessment period | 239 |
Fagan v. The Queen, 2012 DTC 1139 [at 3217], 2011 TCC 523
The taxpayer entered into a flow-through share agreement with a corporation ("991") which he and his colleagues had incorporated for the purpose...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4.01) | 270 |
Administrative Policy
88 C.R. - Q.66
Re the circumstances and method by which RC will require adjustments.
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
Indemnity claims of flow-through shareholder generally disappear on CCAA compromise (pp. 12:27)
[I]n National Bank of Canada v. Merit Energy Ltd.,...
Subsection 66(12.731)
Administrative Policy
23 December 2020 External T.I. 2020-0874621E5 - Administration of Draft Legislation-FTS Extension
COVID-related proposed amendments (principally ss. 66(12.6001), 66(12.731) and 211.91(2.1)) released on December 16, 2020 generally relating to a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 211.91 - Subsection 211.91(2.1) | taxpayers can delay flow-through share reporting under the look-back rule in reliance on the CODID-related proposed amendments | 200 |
Subsection 66(14.5) - Penalty for late designation
Administrative Policy
89 C.P.T.J. - Q25
There is no provision for waiver of this penalty and an amended election will not be accepted unless accompanied by payment of the penalty.
Subsection 66(15) - Definitions
Canadian Resource Property
Cases
Markin v. The Queen, 96 DTC 6483, [1996] 3 CTC 212 (FCTD)
The taxpayer's employer granted him and other employees a contractual right to receive an undivided 0.5% of net profits attributable to the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | 121 | |
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(3) | 128 |
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
The taxpayer paid $4 million to Amoco in consideration of Amoco granting to the taxpayer the exclusive right to take petroleum from certain...
See Also
Alberta Energy Co. Ltd. v. The Queen, 95 DTC 220, [1995] 1 CTC 2111 (TCC), aff'd 98 DTC 6007 (FCA)
With respect to an "Acquisition Agreement" that the taxpayer entered into with the Alberta Crown, Bonner TCJ. found (at p. 224) that:
"As a...
Administrative Policy
13 March 2013 Internal T.I. 2013-0480511I7 F - Canadian resource property
A government authority conducted scientific studies, environmental assessments and evaluations before granting an exploration permit to...
7 January 2013 External T.I. 2012-0460791E5 - Qualified Farm Property & Oil Reserves
In response to a question "as to whether a taxpayer whose farm property meets the definition as a "qualified farm property"... within the meaning...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(2) | 234 |
2 December 2003 External T.I. 2003-004860A - CRP - Rentals and Royalties
In response to the expressed concern that the proposed amendment requiring that the proposed 90% test (quoted below) might require that the...
Income Tax Technical News, No. 10, 11 July 1997: "Net Profits Interests and Proposed Section 18.1"
Discussion of the circumstances in which the inclusion of non-production sources of income in a net profits interest will cause it to not qualify...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account | 0 |
21 August 1995 External T.I. 9514935 - CANADIAN RESOURCE PROPERTY
"'Real Property' generally refers to land and rights issuing out of, annexed to and exercisable within or about land ... . '[M]ineral resource...
94 CPTJ - Q. 21 (941034)
Once it is determined that a particular net profits interest does not qualify as a Canadian resource property (in this context, because of a right...
88 CPTJ - Q.16
A net profits interest entitling the holder to share in the net proceeds of production and sale of oil or gas is a Canadian resource property by...
Articles
Randy S. Morphy, Kim Maguire, "An Update on the Taxation of Farm-outs", Resource Sector Taxation, Vol. IX, No. 3, 2013, p. 661.
Farm-out coupled with transfer for consideration (p. 664)
CRA Document 2011-0420451E5(F) (November 22, 2011) is a recent external technical...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 66.2 - Subsection 66.2(5) - cumulative Canadian development expense - Element F | 302 |
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
The amended version of para. (d) partly codifies the CRA's previous position (in Income Tax Technical News. No. 10), as to when a net profits...
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).
Paragraph (d)
Administrative Policy
7 June 2017 CPTS Roundtable, 2017-0695131C6
Does the reference in para. (d) of the Canadian resource property ("CRP") definition, in its application to a rent or royalty, to the payer...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Proceeds of Disposition | Q.1 - Daishowa extends beyond reforestation and reclamation obligations only on a case-by-case basis | 213 |
| Tax Topics - Treaties - Income Tax Conventions - Article 13 | Q.3 - Canada-U.K. Treaty does not exempt shares deriving their value from Canadian oil and gas licences – even where the Canadian business is carried on “in” them | 193 |
| Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(ii) | Q.4 - by analogy to mining, hydrocarbons may be similar properties | 348 |
| Tax Topics - Income Tax Regulations - Regulation 1101 - Subsection 1101(1) | Q.5 - normal course dispositions of oil and gas properties generally are not of a separate business | 131 |
| Tax Topics - Income Tax Act - Section 4 - Subsection 4(1) | Q.5 - application of Scales test to determining whether there is a separate business | 224 |
| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 26 | Q.7 - refinery catalysts are Class 26 property | 87 |
| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 49 | Q.8 - taxpayers generally have the documentary evidence on hand to allocate costs between pipelines and pipeline appendages | 117 |
Flow-Through Share
Cases
Canada v. JES Investments Ltd., 2007 DTC 5608, 2007 FCA 337
An exploration company ("Deena") that entered into an agreement styled as a flow-through share agreement with the taxpayer failed to incur any...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 6202.1 - Subsection 6202.1(1) | 107 |
Administrative Policy
5 September 2014 External T.I. 2014-0534941E5 - Flow-through share ss 66(15) of the Income Tax Act
Does a right to acquire a share of a principal-business corporation qualify as a flow-through share where the share to be acquired under the right...
28 November 2010 CTF Annual Roundtable, 2010-0384341C6 - Flow-through Shares
Respecting whether CEE can be renounced under a unit flow-through share agreement in respect of the portion of the subscription price allocated to...
6 September 1994 External T.I. 9419865 - ARE SPECIAL WARRANTS FLOW-THROUGH SHARES?
Special warrants would qualify as flow-through shares due to the reference in the post-amble of the definition of rights to have a share issued.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 49 - Subsection 49(3) | 51 |
6 December 1989 T.I. (May 1990 Access Letter, ¶1218)
Discussion of various issues respecting a public offering of flow-through shares.
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
Whether deletion of using look-back rule results in a new agreement rather than the shares being issued pursuant to the actual old flow-through...
Emmanuel Sala, "Flow-Through Share Financing: Recent Developments, Traps and Tips", 2015 CTF Annual Conference paper
Assimilation of warrants to flow-through shares (pp. 10:22-23)
Issuers have been able to treat warrants as flowthrough shares without worrying...
Foreign Exploration and Development Expenses
Administrative Policy
90 C.P.T.J. - Q.36
There is no FEDE incurred by a taxpayer for the purposes of ss.66(15)(e) and 66(4) with respect to U.S. oil and gas drilling expenses incurred by...
Joint Exploration Corporation
Administrative Policy
23 June 1992 T.I. 921868 (January - February 1993 Access Letter, p. 20, ¶C56-211)
A principal business corporation that has, throughout its existence, always been a wholly-owned subsidiary of another corporation will qualify as...
5 September 1991 T.I. (Tax Window, No. 9, p. 19, ¶1446)
A principal business corporation will not be disqualified as a JEC solely by virtue of having had, in the aggregate, more than ten shareholders...
Original Owner
Administrative Policy
94 C.P.T.J. - Q. 10
A person who has an interest in a partnership does not own a proportion or share of the partnership's property for purposes of s. 66.7, except...
Principal-Business Corporation
Cases
Wardean Drilling Co. Ltd. v. M.N.R., 78 DTC 6202, [1978] CTC 270 (FCTD)
It was indicated, obiter, that s. 83A(8a) of the pre-1972 Act, which referred to a principal business which was a gas business or a mining...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Evidence | 27 | |
| Tax Topics - Income Tax Act - Section 66 - Subsection 66(6) | 129 |
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
The activity of buying natural gas from approximately 100 producers of natural gas and selling that natural gas primarily (but not exclusively) to...
M.W.A. Gas and Oil Ltd. v. MNR, 74 DTC 6123, [1974] CTC 140 (FCTD)
The taxpayer, which was incorporated in 1966 to do construction work on a turn-key Ford construction assembly plant, had completed its work by...
Sogemines Development Co. Ltd. v. MNR, 72 DTC 6254, [1972] CTC 284 (FCTD)
The principal business of the parent of the taxpayer was found not to be mining or exploring for minerals in light of the following facts: its...
Minister of National Revenue v. Consolidated Mogul Mines Limited, 68 DTC 5284, [1968] CTC 429, [1969] S.C.R. 54
In its 1957 to 1960 taxation years, the taxpayer carried on exploration work on properties in which it had a direct interest. However, its chief...
See Also
Ethyl Corp. of Canada Ltd. v. The Queen, 80 DTC 6194, [1980] CTC 198 (FCA)
"Petroleum products" are products that are derived from petroleum and accordingly do not include antiknock compound which contains foreign...
Administrative Policy
S3-F8-C1 - Principal-business Corporations in the Resource Industries
Meaning of petroleum products in s. 66(15)(a)
1.4 …[P]etroleum products…in paragraph (a) of the PBC definition, includes all steps up to the...
11 July 1989 T.I. (Dec. 89 Access Letter, ¶1046)
A Canadian corporation whose only activity was mineral exploration for other corporations on a cost plus basis and which did not own any of the...
89 C.P.T.J. - Q10
A holding corporation will not be a principal-business corporation by virtue only of the activities of its grandchild subsidiary.
88 CPTJ - Q.8
RC continues to use the 90% rule as a general guideline for assessing.
86 C.R. - Q.6
Whether a corporation involved in resource activities and having investment assets is engaged in the business of investing those assets is a...
Production
Administrative Policy
10 February 1999 External T.I. 9826855 - PRIME METAL STAGE OR ITS EQUIVALENT
Discussion of what is the "prime metal stage or its equivalent".
Paragraph 66(15)(i)
Administrative Policy
93 C.P.T.J. - Q.31
Where a shareholder invests $100 in shares of a JEC at the beginning of the year, during that year the JEC incurs $1,000 of CDE financed out of...
89 C.P.T.J. - Q.3
It is not a requirement that a shareholder's payment or loan to a JEC be traceable to specific expenses that the JEC subsequently renounces.