Subsection 66.4(5) - Definitions
Mr. A, a U.S. resident, grants the right to drill for or take the oil & gas from his Canadian freehold property to a Canadian company, in...
|Locations of other summaries||Wordcount|
|Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(iii.1)||negative CCDE pool for non-resident individual||176|
|Tax Topics - Income Tax Regulations - Regulation 805||application to resource royalties||252|
|Tax Topics - Treaties - Income Tax Conventions - Article 12||non-application of Art. 12 of US Treaty to resource royalties||142|
|Tax Topics - Treaties - Income Tax Conventions - Article 6||negative CCDE gain from grant of oil and gas royalty not exempt under US Treaty||180|
The taxpayer inherited subsurface exploration rights from his father with a deemed cost under s. 70(5.2) equal to their fair market value, and...