The Alberta government granted a reduction in the royalties the taxpayer otherwise would have been required 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 was not an amount received
d7 import status
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