7-911524
SUBJECT: Royalty Interests/Canadian Resource Property
Further to our telephone conversation on June 5, 1991, attached is a copy of correspondence dated April 18, 1990 pertaining to the interpretation of a "royalty computed by reference to the amount or value of production from a mineral resource in Canada" in subparagraph 66(15)(c)(v) of the Income Tax Act.
Please contact the writer if we can be of any assistance.
Yours truly,
Section ChiefResource Industries SectionBilingual Services and Resource Industries DivisionRulings Directorate