Qualifying environmental 
trust

See discussion on page 26 and following.

Qualified resource expense

See discussion on page 33.

Regulations

The Income Tax Regulations (Canada) promulgated under 
the ITA.

Resource deduction or 
resource expense

Canadian development expense, Canadian exploration expense, 
Canadian oil and gas property expense, foreign exploration and 
development expense, or foreign resource expense.

Resource property

A mining property or an oil and gas property.

Resource surcharge

A capital tax imposed by Saskatchewan on large resource 
companies and resource trusts, equal to 3.0% of the value of 
sales of potash, uranium, and coal produced in Saskatchewan.

SIFT entity

A specified flow-through partnership or trust resident in Canada 
the units of which have a public market and that holds property 
that constitutes non-portfolio property.

SIFT legislation

Legislation that imposes a tax on income from a business 
carried on in Canada by a SIFT entity.

Successor

See discussion on page 14 and following.

Surplus rules

See discussion on page 38 and following.

Stub period

See discussion on page 33.

Tax-free surplus balance

See discussion on pages 45.

Taxable capital gain

One-half of a capital gain.

Taxable surplus

See discussion on page 38.

Tax information exchange 
agreement

A bilateral agreement entered into by two countries to exchange 
information for tax purposes.

Testamentary trust

A trust that takes effect on the death of its creator.

Undepreciated capital cost

The portion of the cost of a depreciable property of a particular 
class prescribed by the Regulations that has not been deducted 
from income in previous years. Calculated as the cost of the 
property less the capital cost allowance claimed for that class of 
property in previous years.

Working interest

The right that a person receives from the owner of the resource 
to drill and mine for minerals or to take petroleum, natural gas, or 
related hydrocarbons. Frequently the Crown is the owner of the 
resource but, in the case of freehold rights, the working interest 
holder will be someone to whom the Crown has granted the 
resources.

© 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