Non-portfolio property

Includes Canadian resource properties, Canadian real property, 
and shares or securities of another entity that have a value in 
excess of 10% of the value of the subject entity.

Non-qualifying active 
business income

Active business income earned in a non-treaty or non-TIEA 
country.

Oil and gas property

Includes any right, licence, or privilege to take petroleum, natural 
gas, or related hydrocarbons; rental or royalty interests in an oil 
or gas well; and any land that derives its principal value from its 
petroleum or natural gas content.

Original owner

The person who incurred resource expenses that a successor 
may deduct in accordance with the successor corporation rules.

Partnership

A business carried on in common with a view to profit by the 
members of the partnership.

Person

An individual, a trust, or a corporation. A partnership is not a 
person for the purposes of the ITA except where expressly 
provided. A joint venture is not a person for tax purposes. 

Pertinent loan or 
indebtedness

See discussion on page 41.

Pre-acquisition surplus

See discussion on page 38.

Predecessor owner

A person who acquires properties from an original owner and 
transfers them to a successor in accordance with the successor 
corporation rules.

Pre-production mining 
expenditure

Canadian exploration expenses incurred on a mineral deposit 
from which the principal mineral to be extracted is diamonds, 
base metals, or precious metals.

Principal-business 
corporation

A corporation whose principal business includes:

• mining or exploring for minerals;
• processing mineral ores for the purposes of recovering 

metals therefrom;

• the production, refining or marketing of petroleum, 

petroleum products or natural gas; or

• exploring or drilling for petroleum or natural gas; and

all or substantially all of the assets of which are shares of the 
capital stock or indebtedness of one or more other corporations 
that are related to the corporation and whose principal business 
is described in the foregoing items. 

A principal-business corporation may be a Canadian corporation 
or a foreign corporation.

Qualifying CEE and 
qualifying CDE

Canadian exploration expense and Canadian development 
expense that may be renounced in accordance with the 
flow-through share rules.

© 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.

 Glossary 

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