Midwest Oil Production Ltd. v. The Queen, 82 DTC 6092, [1982] CTC 107 (FCTD), aff'd 83 DTC 5304, [1983] CTC 338 (FCA) -- summary under Paragraph 12(1)(o)

Because the word "receivable" relates to a change in custody or possession, not to a change in ownership, a royalty obligation to deliver crude oil to the Alberta government (or its agent) that already belonged to it gave rise to an amount being receivable by it. The amount receivable is not reduced by available Alberta drilling incentive credits.

Because s. 12(1)(o) taxes the producer, not the (Alberta) owner, of the petroleum, it does not contravene the constitutional prohibition against the taxation of provincial property.