Partnerships,
7, 10, 26, 28, 31, 33, 34
Permanent establishment,
7
Pertinent loan or indebtedness,
41
Pre-production mining expenditure,
24
Prince Edward Island,
7, 8, 24, 63, 68, 69
Provincial sales tax (PST),
68-69
Qualified resource expense,
33
Qualifying environmental trust,
25
Québec,
25-27, 57, 59-61, 69-70
allowance for a mine in northern Québec,
59
depreciation allowance,
59
exploration and development expense,
59
integrity rules (proposed),
60
investment tax credit,
27
minimum mining tax (proposed),
60
mining tax on annual profit (proposed),
60
non-refundable credit (on account of proposed minimum
mining tax),
61
processing allowance,
59
Québec sales tax (QST),
69
refundable credit for losses,
59
resource tax credit,
26-27
value of precious stones,
59
Repatriation of profits,
46
Saskatchewan,
4, 7, 8, 51-53, 59, 70, 73
coal,
52
diamonds,
52
potash,
51
precious and base minerals,
53
resource surcharge,
51-53, 73
Saskatchewan resource credit,
52
uranium,
52
Scientific research and experimental development credit,
25
SIFT legislation,
7, 10, 11, 33, 34
Successor corporation rules,
14, 15, 17, 28, 29, 30, 31, 46
acquisition of control,
9, 18, 28, 30, 31, 45
amalgamation,
9, 16, 17, 18, 28, 29, 45
original owner,
15, 16
predecessor owner,
15, 16
successor,
14-18, 28-31, 46
wind-up,
29-30
Surplus rules,
38
Takeover,
45
Tariffs,
71
machinery and equipment,
71
ores and concentrates,
71
temporary importations,
71
Tax information exchange agreements,
37
Taxable capital gains,
33, 39-40
Tax-deferred transfers,
29
wind-up,
29
Tax treaties,
44-47
Trusts,
7, 9, 10, 25, 28, 34, 73, 77
Undepreciated capital cost,
18
United States,
47, 74-77
allowable deductions,
75
capital gains,
76-77
capital losses,
76
depletion,
75
depreciable property,
75
disposition of property,
76
domestic production activities deduction,
76
passive foreign investment company,
77
qualifying electing fund,
77
research and development tax credits,
75
US real property interest,
77
Upstream loan rules,
39-40
Wind-up,
9, 17, 18, 29, 30, 45
Withholding tax
Canadian,
41, 44, 47
foreign,
36-39
Yukon,
7, 8, 64, 66, 67, 69
coal royalty,
52
gold royalty,
64
mining royalty,
66-67
© 2013 KPMG LLP, a Canadian limited liability partnership and a member firm of the KPMG network of independent member firms
affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
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A Guide to Canadian Mining Taxation