Imperial Oil Resources Limited v. Canada (Attorney General), 2008 DTC 6657, 2008 FC 1037 -- summary under Paragraph 12(1)(x)

By services, 28 November, 2015

The Alberta government gave the taxpayer a reduction in the royalties it would otherwise have to pay to Alberta on condition that the taxpayer invest in an expansion of the Syncrude project. In finding that s. 12(1)(x) did not apply to this reduction, O'Reilly, J. noted that this reduction formed an integral part of the royalty formula for the expanded project, and none of the components of the calculation could fairly be isolated from the rest and characterized separately.

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embedded royalty reduction
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333755
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