Section 66.1

Subsection 66.1(2) - Deduction for certain principal-business corporations

Administrative Policy

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

12 December 2012 External T.I. 2012-0462511E5 - Canadian Resource Property - Sale- CEE

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 66.1(3) - Expenses of other taxpayer

Administrative Policy

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 66.1(6) - Definitions

Canadian exploration expense

Paragraph (a)

Cases

Canada v. McLarty, 2008 DTC 6354, 2008 SCC 26, [2008] 2 S.C.R. 79

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) 181
Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) decision making not subordinated to the other/structured arrangement 124

Petro-Canada v. Canada, 2004 DTC 6329, 2004 FCA 158

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) joint purchase with no separate interests 117
Tax Topics - Income Tax Act - Section 67 107
Tax Topics - General Concepts - Purpose/Intention purpose test satisfied even if multiple purposes 71

Global Communications Ltd. v. Canada, 99 DTC 5377 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 67 33

The Queen v. Gulf Canada Ltd., 92 DTC 6123 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 124.1 - Subsection 124.1(1) 54
Tax Topics - Statutory Interpretation - Comparison of Provisions presumption that word's meaning is consistent 38

See Also

McLarty v. The Queen, 2005 DTC 217, 2005 TCC 55, rev'd 2006 DTC 6340, 2006 FCA 152, aff'd supra.

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

8 December 2015 External T.I. 2015-0616321E5 F - CEE - Severance pay

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

93 CPTJ - Q.12

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

93 CPTJ - Q.11

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Paragraph (b)

Cases

Canada v. Resman Holdings Ltd., 2000 DTC 6350 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
accumulation

Paragraph (c)

Cases

Edmonton Liquid Gas Ltd. v. The Queen, 84 DTC 6526, [1984] CTC 536 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

See Also

Farmers Mutual Petroleums Limited v. Minister of National Revenue, 67 DTC 5277, [1967] CTC 396, [1968] S.C.R. 59

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

88 CPTJ - Q.1

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

88 CPTJ - Q.18

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

88 CPTJ - Q.19

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Paragraph (d)

Cases

Canada v. Resman Holdings Ltd., 2000 DTC 6350 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

94 C.P.T.J. - Q.14

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2.11) 21

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

89 C.P.T.J. - Q.18

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

89 C.P.T.J. - Q.17

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Paragraph (e)

Administrative Policy

11 January 2005 Internal T.I. 2004-010434 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Paragraph (f)

Cases

Canada v. Phénix, 2001 DTC 5367 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

See Also

Mickleborough v. The Queen, 99 DTC 47 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Agency - Agency 62

Administrative Policy

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 66 - Subsection 66(12.71) U.S. public corporation can issue flow-through shares for CEE performed under a farm-in agreement with a Canadian sub 368

2017 Ruling 2016-0635341R3 - Canadian Exploration Expenses - New Mine

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

16 June 2017 External T.I. 2016-0674541E5 - Mineral Certification

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Mineral Resource placer jade deposit did not qualify as a non-bedded deposit of industrial mineral or as a base or precious metal deposit 88

2016 Ruling 2016-0639671R3 - Exploration expenses as CEE

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

24 January 2017 Internal T.I. 2016-0675902I7 - Canadian exploration expense

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

2015 Ruling 2014-0534121R3 - Canadian Exploration Expenses - New Mine

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

2012 Ruling 2011-0422761R3 - Canadian Exploration Expenses

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

21 January 2004 External T.I. 2003-004520 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

5 November 2003 Internal T.I. 2003-001803 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

2002 Ruling 2002-016729 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

24 July 2002 External T.I. 2001-013315 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

2001 Ruling 2001-008113 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

8 November 1993 T.I. 933205 (C.T.O. "Expenses Prior to Mineral Resource Certification")

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

1 March 1991 T.I. 7-4631

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Articles

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subparagraph (vi)

See Also

ARQ v. Wesdome Gold Mines Ltd., 2018 QCCA 518 (Queb. C.A.)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) a reassessment of a wound-up and dissolved sub bound its parent 389
Tax Topics - Other Legislation/Constitution - Federal - Canada Business Corporations Act - Section 226 - Subsection 226(2) assessment issued in name of sub after its dissolution but also after its audit bound and was appealable by parent 242

Wesdome Gold Mines Ltd. v. ARQ, 2016 QCCQ 1504

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Paragraph (g)

Cases

Oro Del Norte S.A. v. The Queen, 93 DTC 5217 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
mineral resource

See Also

Teck-Bullmoose Coal Inc. v. The Queen, 97 DTC 792 (TCC), aff'd 98 DTC 6363, Docket: A-949-96 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Placer Dome Inc. v. The Queen, 93 DTC 235 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

2012 Ruling 2011-0408981R3 - Canadian Exploration Expenses

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

2004 Ruling 2004-008972 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

2000 Internal T.I. 2000-0044071I7 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

11 December 2003 External T.I. 2003-004378 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

91 CPTJ - Q.28

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

November 1991 Memorandum (Tax Window, No. 12, p. 21, ¶1565)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

November 1991 Memorandum (Tax Window, No. 12, p. 16, ¶1569)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

87 C.R. - Q.47

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Paragraph (g.3)

Administrative Policy

11 October 2017 Internal T.I. 2017-0719181I7 F - Agreement in writing

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (g.4) pre-production mine development expenses that qualify under CEE – (g.4) need not qualify under (g.3) 243

Paragraph (g.4)

Administrative Policy

11 October 2017 Internal T.I. 2017-0719181I7 F - Agreement in writing

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (g.3) unresolved ambiguity re whether agreement can refer to a subcontracting agreement 100

Paragraph (h)

Administrative Policy

16 March 1990 T.I. (August 1990 Access Letter, ¶1374)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

22 March 1988 T.I. (August 1990 Access Letter, ¶1374)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Paragraph (i)

Administrative Policy

86 C.R. - Q.4

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

cumulative Canadian exploration expense

Element G

Administrative Policy

12 January 2015 External T.I. 2014-0555071E5 - POD subject to earn-out

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(g) proceeds of goodwill on sale of wind turbine development project 193
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Cumulative Eligible Capital proceeds of goodwill on sale of wind turbine development project 225
Tax Topics - Income Tax Regulations - Regulation 1219 - Subsection 1219(1) wind turbine development project 102

Element J

Administrative Policy

89 C.P.T.J. - Q19

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

88 C.P.T.J. - Q2

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

88 C.P.T.J. - Q4

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 66.1(9) - Canadian development expenses for preceding years

Administrative Policy

11 January 2005 Internal T.I. 2004-010434 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.