Regulation 1204

Subsection 1204(1)

Cases

3850625 Canada Inc. v. The Queen, 2010 DTC 1089 [at 2976], 2010 TCC 104, aff'd 2011 DTC 5062 [at 5714], 2011 FCA 117

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Gulf Canada Resources Ltd. v. The Queen, 95 DTC 5189 (FCTD), partially rev'd 96 DTC 6065 (FCA).

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Echo Bay Mines Ltd. v. The Queen, 92 DTC 6437 (FCTD)

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Words and Phrases
hedge

International Nickel Co. of Canada Ltd. v. MNR, 71 DTC 5332 (FCTD)

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See Also

ATCO Electric Ltd. v. The Queen, 2007 DTC 974, 2007 TCC 243

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Astral Energy Ltd. v. MNR, 90 DTC 1844 (TCC)

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Administrative Policy

29 November 2012 Internal T.I. 2012-0462361I7 - Meaning of "Prime Metal Stage or its Equivalent"

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 65 145

26 January 1996 External T.I. 9603015 - RESOURCE PROFITS, DIAMONDS, PRIME METAL STAGE

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27 July 1995 Internal T.I. 9514966 - CAPITAL TAX - RESOURCE PROFITS

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24 December 1992 Memorandum (Tax Window, No. 27, p. 14, ¶2337)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Computation of Profit 59

92 C.R. - Q.17

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89 C.R. - Q.22

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Timing 42

89 C.P.T.J. - Q21

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89 C.P.T.J. - Q22

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89 C.P.T.J. - Q23

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Paragraph 1204(1)(b)

See Also

Placer Dome Canada Ltd. v. Ontario (Minister of Finance), 2006 DTC 6532, 2006 SCC 20, [2006] 1 S.C.R. 715

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Words and Phrases
consideration
Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Interpretation Bulletins, etc. shifting CRA position could not be relied upon except to evidence ambiguity 79
Tax Topics - Statutory Interpretation - Redundancy/reading in words presumption against tautology 120
Tax Topics - Statutory Interpretation - Resolving Ambiguity residual presumption in favour of the taxpayer 133
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Futures/Forwards/Hedges “hedging “ includes cash settled derivatives including options 461
Tax Topics - Statutory Interpretation - Regulations/Statutory Delegation addition of regulation did not significantly expand scope of tax 259

Subparagraph 1204(1)(b)(ii)

See Also

Barrick Gold Corporation v. The Queen, 2017 TCC 18

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Accounting Principles character of hedging gain was a legal question not affected by accounting 119

Paragraph 1204(1)(f)

Administrative Policy

27 July 1995 Internal T.I. 9514966 - CAPITAL TAX - RESOURCE PROFITS

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Subsection 1204(1.1)

Administrative Policy

20 January 2010 Internal T.I. 2009-0348571I7 - Interest Rate Swaps and Resource Profits

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15 September 2000 External T.I. 2000-0027485 - Hedging Losses in Resource Profit Calculation

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Articles

Richardson, "Cominco, Westar, and the Legacy of a Gulf", 1993 Canadian Tax Journal, Vol. 41, No. 4, p. 672.

Subsection 1204(3)

Cases

Paragraph 1204(3)(a)

See Also

Exxonmobil Canada Ltd. v. The Queen, 2019 TCC 108

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Words and Phrases
derived
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Scientific Research & Experimental Development initial well placed in order to validate improved reservoir analysis was not SR&ED 326

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