Tuesday, May 28, 2013 9:17:42 PM
AGREE, TINKERBELLE!!
KATX IS AN EMPTY SHELL WITH LOTS OF VALUE!!!!!!!!!
Exploration surface tax credits are worth a lot of money to whomever takes over. I refer you to page 4 of this link:
http://www.pwc.com/en_ca/ca/mining/publications/canadian-mining-taxation-2011-04-en.pdf
There are 15 percent exploration surface tax credits, but when control of a company is acquired, all net capital loss carryovers are lost and the subsequent deduction of pre-control non-capital loss carryovers becomes restricted. Generally speaking, pre-control non-capital business losses are restricted to a deduction against income from a business that produces the same or similar products. In addition, a tax year is deemed to end immediately before the acquisition of control, effectively accelerating the expiry of any non-capital loss carryover.
And also read page 10:
The income tax legislation dealing with exploration and development expenditures reflects an underlying policy that income tax relief should be available in respect to those expenditures, even to a taxpayer that did not necessarily incur the expense (as long as a deduction is claimed only once in respect of any particular expense). To this end, the so-called “successor corporation” rules of the Income Tax Act contain complicated provisions that, in certain circumstances, allow the unclaimed exploration and development expense balances of a particular taxpayer to be “inherited” by another corporation.
A corporation (the successor corporation becomes entitled to deduct in subsequent years an amount in respect of a transferor’s (the predecessor’s) unclaimed CCEE, CCDE and FEDE (or FRE) balances, if the successor corporation:
--Acquired “all or substantially all” of the predecessor’s Canadian and foreign resource properties; and
--jointly elected with the predecessor in a prescribed manner.
KATX IS AN EMPTY SHELL WITH LOTS OF VALUE!!!!!!!!!
Exploration surface tax credits are worth a lot of money to whomever takes over. I refer you to page 4 of this link:
http://www.pwc.com/en_ca/ca/mining/publications/canadian-mining-taxation-2011-04-en.pdf
There are 15 percent exploration surface tax credits, but when control of a company is acquired, all net capital loss carryovers are lost and the subsequent deduction of pre-control non-capital loss carryovers becomes restricted. Generally speaking, pre-control non-capital business losses are restricted to a deduction against income from a business that produces the same or similar products. In addition, a tax year is deemed to end immediately before the acquisition of control, effectively accelerating the expiry of any non-capital loss carryover.
And also read page 10:
The income tax legislation dealing with exploration and development expenditures reflects an underlying policy that income tax relief should be available in respect to those expenditures, even to a taxpayer that did not necessarily incur the expense (as long as a deduction is claimed only once in respect of any particular expense). To this end, the so-called “successor corporation” rules of the Income Tax Act contain complicated provisions that, in certain circumstances, allow the unclaimed exploration and development expense balances of a particular taxpayer to be “inherited” by another corporation.
A corporation (the successor corporation becomes entitled to deduct in subsequent years an amount in respect of a transferor’s (the predecessor’s) unclaimed CCEE, CCDE and FEDE (or FRE) balances, if the successor corporation:
--Acquired “all or substantially all” of the predecessor’s Canadian and foreign resource properties; and
--jointly elected with the predecessor in a prescribed manner.
