Subsection 66.1(2) - Deduction for certain principal-business corporations
Administrative Policy
S3-F8-C1 - Principal-business Corporations in the Resource Industries
Overview
1.21 Subsection 66.1(2) provides a special rule for computing the amount deductible by certain PBCs [principal business corporations] for...
12 December 2012 External T.I. 2012-0462511E5 - Canadian Resource Property - Sale- CEE
A corporation which disposes of all or substantially all of its Canadian resource property in a transaction that is subject to the successor rules...
Subsection 66.1(3) - Expenses of other taxpayer
Administrative Policy
S3-F8-C1 - Principal-business Corporations in the Resource Industries
Excluded PBCs
1.21 …Subsection 66.1(2) excludes from its application certain PBCs involved with clean energy generation and energy conservation...
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 full purchase price of $100,000 for the acquisition by the taxpayer of seismic data represented Canadian exploration expense to him...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) | 187 | |
| Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) | decision making not subordinated to the other/ structured arrangement | 138 |
Petro-Canada v. Canada, 2004 DTC 6329, 2004 FCA 158
The Tax Court had allowed a deduction for only a portion of the purchase price for seismic data purchased by two joint exploration corporations...
| 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 | 119 |
| Tax Topics - Income Tax Act - Section 67 | paying more than FMV may not engage s. 67 | 109 |
| Tax Topics - General Concepts - Purpose/Intention | purpose test satisfied even if multiple purposes | 77 |
Global Communications Ltd. v. Canada, 99 DTC 5377 (FCA)
The taxpayer purchased a block of seismic data for $1.8 million cash and a $13.2 million note under which recourse was limited to what was...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 67 | 35 |
The Queen v. Gulf Canada Ltd., 92 DTC 6123, [1992] 1 CTC 183 (FCA)
In finding that annual rental or other payments to provincial governments made for the purpose of keeping leases or licences to subsurface oil and...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 124.1 - Subsection 124.1(1) | 56 | |
| Tax Topics - Statutory Interpretation - Comparison of Provisions | presumption that word's meaning is consistent | 44 |
See Also
McLarty v. The Queen, 2005 DTC 217, 2005 TCC 55, rev'd 2006 DTC 6340, 2006 FCA 152, aff'd supra.
The taxpayer purchased an undivided interest in seismic data and related business assets for $100,000 payable, as to $15,000, in cash, and as to...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) | freedom not to transact | 66 |
| Tax Topics - Income Tax Act - Section 67 | 105 |
Administrative Policy
8 December 2015 External T.I. 2015-0616321E5 F - CEE - Severance pay
Would a severance payment made by the taxpayer to an employee who performed services on exploration projects (but whose duties were not all or...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 1206 - Subsection 1206(1) - Canadian exploration and development overhead expense | exclusion of severance payment | 258 |
93 CPTJ - Q.12
Whether a purchaser is acquiring seismic data for use in its exploration business, so that the cost is CEE or whether the purchaser is acquiring...
93 CPTJ - Q.11
The tax treatment accorded by a specific section of the Act overrides the accounting treatment given to the transaction.
The salary cost of a...
Paragraph (b)
Cases
Canada v. Resman Holdings Ltd., 2000 DTC 6350 (FCA)
Before going on to find that expenditures incurred in drilling step-out or delineation wells (i.e., wells drilled at the edge of a known pool of...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (d) | 101 | |
| Tax Topics - Statutory Interpretation - Ordinary Meaning | word accorded its industry meaning | 102 |
Paragraph (c)
Cases
Edmonton Liquid Gas Ltd. v. The Queen, 84 DTC 6526, [1984] CTC 536 (FCA)
Funds expended in 1974 for the drilling in 1975 of what proved to be a dry hole were nonetheless "incurred" in 1974, because under the 1974...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense | expense incurred as no refund rights | 138 |
| Tax Topics - Income Tax Act - Section 245 - Old | 68 | |
| Tax Topics - Statutory Interpretation - Hansard, explanatory notes, etc. | 39 |
See Also
Farmers Mutual Petroleums Limited v. Minister of National Revenue, 67 DTC 5277, [1967] CTC 396, [1968] S.C.R. 59
An agreement between the taxpayer and its parent corporation was characterized as an agreement to pay for a contractual right to acquire an...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees | 168 |
Administrative Policy
88 CPTJ - Q.1
RC uses parameters of the Energy Resources Conservation Board (Alberta) in determining "new pool" status.
88 CPTJ - Q.18
Although the phrase "any expense" can be interpreted very broadly, the object and spirit of the Act does not allow depreciable property to be...
88 CPTJ - Q.19
Financing costs may only be included in resource pools pursuant to section 21.
Paragraph (d)
Cases
Canada v. Resman Holdings Ltd., 2000 DTC 6350 (FCA)
Sharlow J.A. found that expenditures incurred on two wells that were dry holes but where, in one case, the drilling rig contract for the wells was...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (b) | 115 | |
| Tax Topics - Statutory Interpretation - Ordinary Meaning | word accorded its industry meaning | 102 |
Administrative Policy
94 C.P.T.J. - Q.14
A well, which is not an exploratory probe, that is drilled for the purpose of determining the existence of petroleum or natural gas and that...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 87 - Subsection 87(2.11) | 21 |
93 C.P.T.J. - Q.26
Where a well that originally was drilled in 1988 is re-entered in 1993 and drilled to a deeper zone resulting in the discovery of a new pool, well...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 66 - Subsection 66(9) | 49 | |
| Tax Topics - Income Tax Act - Section 66.2 - Subsection 66.2(5) - Canadian development expense - Paragraph (b) | 77 |
90 C.P.T.J. - Q.34
Listing of the more common differences between the ERCB classification system and the definition of CEE.
89 C.P.T.J. - Q.18
The definitions used in the Act do not coincide with the parameters used by the ERCB for classifying wells, which are advance estimates rather...
89 C.P.T.J. - Q.17
It is the status of the well that determines whether the expenses are classified as CEE or CDE, and not the intent of the expenses. RC does not...
Paragraph (e)
Administrative Policy
11 January 2005 Internal T.I. 2004-0104341I7 - Reclassify CDE of partnership to CEE
The word "taxpayer" in subsection 66.1(9) and in paragraph (e) of the definition of CEE should be interpreted as referring only to a partner of a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(9) | 277 | |
| Tax Topics - Statutory Interpretation - Comparison of Provisions | 89 |
Paragraph (f)
Cases
Canada v. Phénix, 2001 DTC 5367 (FCA)
Expenditures that would otherwise qualify as the cost of depreciable property were found to qualify as CEE.
See Also
Ressources Eastmain Inc. v. Agence du revenu du Québec, 2021 QCCQ 4379
In finding that the cost of having a recently-hired employee attend a course on geology at the University of Quebec qualified as Canadian...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 1206 - Subsection 1206(1) - Canadian exploration and development overhead expense - Paragraph (b) | as a junior exploration company’s CEO devoted "substantially all" (75%) of his time to exploration, his salary was not CEDOE | 283 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Current expense vs. capital acquisition | annual expenditures on core sample boxes and racks were capital expenditures, whereas those on dirt berms were currently deductible | 302 |
| Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (k.1) | annual expenditures on core sample boxes and racks were excluded under para. (k.1) | 105 |
Mickleborough v. The Queen, 99 DTC 47, [1998] 4 CTC 2584 (TCC)
Various expenses incurred in connection with the operation and supply of a pilot mill that was used in a bulk sampling operation qualified as CEE...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Agency - Agency | 64 |
Administrative Policy
2023 Ruling 2023-0961681R3 - CEE Incurred by a Non-resident
Exploration background
The Company (a taxable Canadian corporation and a principal business corporation (“PBC”)) holds the former-mining...
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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 |
| 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 |
9 February 2022 External T.I. 2020-0873931E5 - CEE - Economic Assessments
Regarding whether the test of incurring an expense “for the purpose of determining the existence, location, extent, or quality of a mineral...
9 February 2022 Internal T.I. 2020-0873931I7 - Cover Letter - Mining Expenditure Review Table
Items included in para. (f) of Canadian exploration expense include:
- Planning the exploration program and reviewing previous exploration...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Current expense vs. capital acquisition | studies made before a decision to bring a mine into production are currently deductible | 117 |
| Tax Topics - Income Tax Act - Section 66.2 - Subsection 66.2(5) - Canadian development expense - Paragraph (e) | mineral claims and exploration permits included | 21 |
2020 Ruling 2019-0826011R3 - Underground Mine
Background
The Company purchased the Project, including Property A (on which there is a continuous, massive deposit (the Deposit”)) consisting...
21 February 2019 Internal T.I. 2019-0796791I7 - Mining Expenditure Review Table
CRA categorized different types of pre-mining expenditures, including the following:
|
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Start-Up and Close-Down Expenditures | Rio Tinto approach essentially applied to categorization of mine design studies | 94 |
15 November 2018 External T.I. 2018-0762201E5 - Canadian Exploration Expense
In order to secure access to and explore a property (the “Property”) in which an aboriginal community (the “Community”) has asserted an...
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 - 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 | 392 |
2017 Ruling 2016-0635341R3 - Canadian Exploration Expenses - New Mine
History of mine
Some time previously, production ceased at the mine site and the mill was removed. After the property had changed hands a number...
16 June 2017 External T.I. 2016-0674541E5 - Mineral Certification
The Minister of Natural Resources advised CRA that nephrite (a type of jade) to be extracted from the in-situ deposits on the subject property was...
| 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 | 94 |
2016 Ruling 2016-0639671R3 - Exploration expenses as CEE
Background
2014-0534121R3 confirmed that an abandoned mine within the Corporation’s Concession had lost its characteristics as a mine in a...
24 January 2017 Internal T.I. 2016-0675902I7 - Canadian exploration expense
CRA revised its guidelines, summarized below, to reflect the amendment of para. (f) respecting community consultation and environmental study...
2015 Ruling 2014-0534121R3 - Canadian Exploration Expenses - New Mine
History
A former producing mine in the Concession, which was the only workings capable of producing ore, has since been abandoned and is inactive....
2012 Ruling 2011-0422761R3 - Canadian Exploration Expenses
A principal business corporation ("C Co.") plans to engage in an extensive surface exploration program to evaluate several prospective geological...
24 January 2011 Internal T.I. 2010-0389251I7 F - Farm-out agreement and warrants
A mining exploration corporation (the "Purchaser") agreed with another mining exploration corporation (the "Vendor") to acquire an interest in the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (j) | CEE to be incurred under simple farmout reduced by an allocation to warrants issued by farmee | 156 |
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | valuation of “free” warrants issued as part of a simple farmout agreement determined based on what would be a s. 15(1) benefit | 190 |
| Tax Topics - General Concepts - Fair Market Value - Options | amount allocated out of consideration to “free” warrants based on the greater of their trading and in-the-money value | 191 |
20 June 2006 External T.I. 2005-0149651E5 F - CEE / FEC
The results of preliminary exploration work indicated that further exploration of the “Property” was warranted – but this would require work...
21 January 2004 External T.I. 2003-0045201E5 - Underground exploration program - CEE?
After an underground mine had been in commercial production, it was placed on care and maintenance, and broken ore and mining equipment were...
5 November 2003 External T.I. 2003-001803A - Whether New Mine of Extension
A proposed development program would be considered to constitute an extension of an existing mine (which had gone out of production but had been...
2002 Ruling 2002-016729A - Exploration/Sink Shaft-CEE
Proposed exploration that was adjacent to what had been a mine would qualify as CEE (and the area if brought into production would qualify as a...
24 July 2002 External T.I. 2001-013315
The costs of a proposed exploration and development program that would target zones that would eventually be accessed by extending the existing...
2001 Ruling 2001-0081133 - CEE
Ruling that a proposed mine will be a new mine and that development work, bulk sample testing and drilling to confirm a threshold mineral...
8 November 1993 Income Tax Severed Letter 9332055 - Expenses Prior to Mineral Resource Certification
Once a mineral deposit is certified pursuant to paragraph (d)(i) of the definition of "mineral resource" in s. 248(1), the deposit will be...
1 March 1991 T.I. 7-4631
"Generally, our position on feasibility studies is that they are too remote from activities undertaken to actually determine the existence,...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense | 26 |
Articles
Emmanuel Sala, "Flow-Through Share Financing: Recent Developments, Traps and Tips", 2015 CTF Annual Conference paper
Application of purpose test in (f) (pp. 10:14-17)
Revenue Quebec is of the opinion that expenses that are incidental to exploration work qualify...
Subparagraph (vi)
See Also
ARQ v. Wesdome Gold Mines Ltd., 2018 QCCA 518 (Queb. C.A.)
A mining company (“McWatters”) operated its Kiena gold mine, whose primary facilities were situated at Lac de Montigny near Val-d’Or, until...
| 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 | 439 |
| 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 | 254 |
Wesdome Gold Mines Ltd. v. ARQ, 2016 QCCQ 1504
A mining company (“McWatters”) operated its Kiena gold mine, whose primary facilities were situated at Lac de Montigny near Val-d’Or, until...
Paragraph (g)
Cases
Oro Del Norte S.A. v. The Queen, 93 DTC 5217, [1993] 1 CTC 245 (FCTD)
Expenses incurred by members of a joint venture, including the taxpayer, in connection with preliminary planning for an underground mine that was...
See Also
Teck-Bullmoose Coal Inc. v. The Queen, 97 DTC 792 (TCC), aff'd 98 DTC 6363, Docket: A-949-96 (FCA)
The taxpayer's share of expenditures made by a joint venture to build an improved road linking a proposed coal-mining site to a railroad did not...
Placer Dome Inc. v. The Queen, 93 DTC 235, [1993] 1 CTC 2411 (TCC)
An underground mining operation was a new mine rather than an expansion of the open pit mine which lay above it, given that it constituted a...
Administrative Policy
2012 Ruling 2011-0408981R3 - Canadian Exploration Expenses
A mine to be developed close to an existing mine (the C Mine) is ruled to be a new mine within a mineral resource in Canada for purposes of s. (g)...
2004 Ruling 2004-0089721R3 - Exploration/new mine- CEE?
"It is our view that expenses that do not meet the purpose test in paragraph (f) of the definition of Canadian exploration expense will only be...
11 October 2000 Internal T.I. 2000-0044071I7 - Environmental Assessment Expenses
As expenses incurred prior to a decision having been made to proceed with a particular mining project do not satisfy the test in (g),...
11 December 2003 External T.I. 2003-0043785 - CEE/CDE Various Expenses
"The nature and type of expenses contemplated by paragraph (g) of the definition of CEE are mine development expenses incurred after the decision...
91 CPTJ - Q.28
Discussion of when pre-production costs will be eligible for inclusion in CEE.
November 1991 Memorandum (Tax Window, No. 12, p. 21, ¶1565)
Re whether a mine is a "new mine".
November 1991 Memorandum (Tax Window, No. 12, p. 16, ¶1569)
Operating losses incurred prior to the beginning of commercial production of a mine may qualify as CEE if they are shown as an asset on the...
87 C.R. - Q.47
a placer mine comes into production when full-scale sluicing commences.
Paragraph (g.3)
Administrative Policy
11 October 2017 Internal T.I. 2017-0719181I7 F - Agreement in writing
One of the para. (g.3) conditions is that the pre-production mine development expenses were incurred under an agreement entered into before March...
| 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) | 253 |
Paragraph (g.4)
Administrative Policy
11 October 2017 Internal T.I. 2017-0719181I7 F - Agreement in writing
Corporation X, which is a principal-business corporation, issues a flow-through share under a written agreement entered into on December 31, 2012,...
| 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 | 104 |
Paragraph (h)
Administrative Policy
16 March 1990 T.I. (August 1990 Access Letter, ¶1374)
The use of a partnership for the purpose of "warehousing" resource expenditures was offensive in policy terms and, accordingly, RC was unwilling...
22 March 1988 T.I. (August 1990 Access Letter, ¶1374)
CEE and CDE incurred by a partner pursuant to ss.66.1(6)(a)(iv) and 66.2(5)(a)(iv) is treated as being incurred by the partner at the end of the...
Paragraph (i)
Administrative Policy
86 C.R. - Q.4
RC will not disallow CEE claimed by a partner solely on the basis that the terms and conditions of the partnership units do not comply with the...
Paragraph (j)
Administrative Policy
24 January 2011 Internal T.I. 2010-0389251I7 F - Farm-out agreement and warrants
A mining exploration corporation (the "Purchaser") agreed with another mining exploration corporation (the "Vendor") to acquire an interest in the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | valuation of “free” warrants issued as part of a simple farmout agreement determined based on what would be a s. 15(1) benefit | 190 |
| Tax Topics - General Concepts - Fair Market Value - Options | amount allocated out of consideration to “free” warrants based on the greater of their trading and in-the-money value | 191 |
| Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (f) | application of farmout policy to situation where free warrants issued along with incurring of CEE | 214 |
Paragraph (k.1)
See Also
Ressources Eastmain Inc. v. Agence du revenu du Québec, 2021 QCCQ 4379
In finding that the recurring costs of racks and boxes incurred by an exploration company in order to store core samples were capital...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 1206 - Subsection 1206(1) - Canadian exploration and development overhead expense - Paragraph (b) | as a junior exploration company’s CEO devoted "substantially all" (75%) of his time to exploration, his salary was not CEDOE | 283 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Current expense vs. capital acquisition | annual expenditures on core sample boxes and racks were capital expenditures, whereas those on dirt berms were currently deductible | 302 |
| Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (f) | geology course for an employee was necessary to exploration and resource identification | 173 |
Cumulative Canadian exploration expense
Element G
Administrative Policy
12 January 2015 External T.I. 2014-0555071E5 - POD subject to earn-out
In an arm's length sale, the corporate "Vendor" disposes of the "Property" (including land options agreements, permits, engineering data and...
| 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 | 201 |
| Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Cumulative Eligible Capital | proceeds of goodwill on sale of wind turbine development project | 231 |
| Tax Topics - Income Tax Regulations - Regulation 1219 - Subsection 1219(1) | wind turbine development project | 108 |
Element J
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 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 |
| Tax Topics - Income Tax Act - Section 66 - Subsection 66(12.6) - Paragraph 66(12.6)(a) | credit under the Quebec Mining Duties Act based on exploration and development losses of operator was too remote from the exploration to reduce the renounced CEE | 211 |
89 C.P.T.J. - Q19
An amount will be entitled to be received on the date provided for in the applicable senate legislation. For example, an amount will be entitled...
88 C.P.T.J. - Q2
It is RC's practice to allow taxpayers to increase their CCEE/CCDE by assistance (e.g., PIP or CEDIP) in the subsequent year when the assistance...
88 C.P.T.J. - Q4
Only royalty relief that takes the form of a direct royalty reduction (for example, as a credit or as a direct payment received) will reduce the...
Subsection 66.1(9) - Canadian development expenses for preceding years
Administrative Policy
11 January 2005 Internal T.I. 2004-0104341I7 - Reclassify CDE of partnership to CEE
"... paragraph (f) of the definition of CDE (which allocates the partner's share of CDE incurred by the partnership) does not contain any wording...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (e) | 86 | |
| Tax Topics - Statutory Interpretation - Comparison of Provisions | 89 |