19 October 1990 Internal T.I. 9027557 F - Deductibility of Foreign Exploration and Development Expenses

By services, 18 January, 2022
Official title
Deductibility of Foreign Exploration and Development Expenses
Language
French
CRA tags
n/a
Document number
Citation name
9027557
Severed letter type
Technical Interpretation - Internal
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
633951
Extra import data
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"field_release_date_new": "1990-10-19 08:00:00",
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Main text
  October 19, 1990
Audit Programs Directorate Resource Industries
Special Audits Division Section
E.H. Gauthier John Chan
Director 957-9795
B.A. Chisholm 7-902755

SUBJECT:  Oil & Gas Issue Report #04 Foreign Exploration and Development Expenses ("FEDE")

As requested in your memorandum dated September 26, 1990, we confirm that the letters issued by the Rulings Directorate on August 31, 1987 and August 27, 1990 pertaining to the deductibility of FEDE reflect the Directorate's current position with respect thereto.

We are also sending copies of correspondence issued by the Rulings Directorate on June 23, 1987, September 4, 1985 and October 11, 1984 which further support the audit policy on the deductibility of FEDE in your Oil and Gas Issue Report # O&G 04.

A/DirectorBilingual Services and ResourceIndustries DivisionRulings Directorate

Enclosures