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, see here). 

The CRA is accepting comments on this document until July 3, 2015. See here for the folio, and here for a summary of substantive technical and interpretive changes.


Steve Suarez