Grassroots CEE

Canadian exploration expense incurred for the purpose of 
determining the existence, location, extent, or quality of an oil, 
gas, or mineral resource in Canada.

 Gross income

A term used in many mining tax statutes referring to the sale 
proceeds of a product. Gross income is the starting point for 
computing the income that is subject to tax.

 Gross revenue

A term used in many mining tax statutes and that refers to the 
sale proceeds of a product. Gross income is the starting point 
for computing the income that is subject to tax. 

Hybrid surplus

See discussion on page 38.

Inter-vivos trust

A trust that takes effect during the lifetime of its creator.

Investment business

See discussion on page 40 and following.

Investment tax credit

A deduction from tax payable earned by incurring qualifying 
expenses such as pre-production mining expenditures and 
scientific research and experimental development expenses. 

Joint venture

An undertaking carried out by two or more persons pursuant 
to which assets of the business are owned directly by the 
participants in the joint venture. 

Large corporations tax

A federal capital tax that was previously imposed under Part I.3 
of the ITA.

Limited partnership

A partnership in which one or more partners is a general partner 
that manages the business of the partnership and has unlimited 
liability for the debts of the partnership, and one or more 
partners is a limited partner that does not manage the business 
of the partnership and has limited liability for the debts of the 
partnership. 

Mining exploration tax creditSee discussion on page 26 and following.

Mining property

Includes any right, licence, or privilege to prospect, drill, or mine 
for minerals; rental or royalty interests in a mineral resource; and 
any land that derives its principal value from its mineral resource 
content.

Net capital losses

The difference between allowable capital losses and taxable 
capital gains realized on the disposition of capital properties.

Non-capital losses

Net operating losses from a business or a property (i.e., losses 
other than net capital losses).

Non-depreciable capital 
property

Capital property for which a deduction for capital cost allowance 
is not permitted. Includes land (other than a resource property), 
shares, and partnership interests held as an investment to 
produce income.

© 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