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
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A Guide to Canadian Mining Taxation