• CRA Releases Resource Sector ‘Principal Business Corporation’ Folio
  • April 16, 2015 | Author: Steve Suarez
  • Law Firm: Borden Ladner Gervais LLP - Toronto Office
  • The Canada Revenue Agency is updating many of its folios on different tax issues, which summarize the CRA’s interpretation of the law on those issues.

    On April 2, 2015, the CRA released Income Tax Folio S3-F8-C1 Principal-business Corporations in the Resource Industries, which replaces and cancels former Interpretation Bulletin IT-400, Exploration and Development Expenses - Meaning of Principal-Business Corporation. PBC status is relevant in a number of specific mining-sector tax rules: for example, in order to be a “flow-through share” as defined in s. 66(15) ITA, the issuer of the share must be a PBC (for more on flow-through shares and other mining-sector tax issues).

    The CRA is accepting comments on this document until July 3, 2015.