Income Tax Regulations — 1204
1204 (1) For the purposes of this Part, gross resource profits of a taxpayer for a taxation year means the amount, if any, by which the total of (a) the amount, if any, by which the aggregate of (i) the aggregate of amounts, if any, that would be included in computing the taxpayer’s income for the year by virtue of subsection 59(2) and paragraphs 59(3.2)(b) and 59.1(b) of the Act if subsection 59(2) were read without reference to subsection 64(1) therein, and (i.1) the amount, if any, by which the amount included in computing his income for the year by virtue of paragraph 59(3.2)(c) of the Act exceeds the proceeds of disposition of property described in clause 66(15)(c)(ii)(A) of the Act that became receivable in the year or a preceding taxation year and after December 31, 1982 to the extent that such proceeds have not been deducted in determining the amount under this subparagraph for a preceding taxation year exceeds (ii) the aggregate of amounts, if any, deducted in computing his income for the year by virtue of paragraph 59.1(a) and subsections 64(1.1) and (1.2) of the Act, (b) the amount, if any, of the aggregate of his incomes for the year from (i) the production of petroleum, natural gas, related hydrocarbons or sulphur from (A) oil or gas wells in Canada operated by the taxpayer, or (B) natural accumulations (other than mineral resources) of petroleum or natural gas in Canada operated by the taxpayer, (ii) the production and processing in Canada of (A) ore, other than iron ore or tar sands ore, from mineral resources in Canada operated by him to any stage that is not beyond the prime metal stage or its equivalent, (B) iron ore from mineral resources in Canada operated by him to any stage that is not beyond the pellet stage or its equivalent, and (C) tar sands ore from mineral resources in Canada operated by him to any stage that is not beyond the crude oil stage or its equivalent, (iii) the processing in Canada of (A) ore, other than iron ore or tar sands ore, from mineral resources in Canada not operated by him to any stage that is not beyond the prime metal stage or its equivalent, (B) iron ore from mineral resources in Canada not operated by him to any stage that is not beyond the pellet stage or its equivalent, and (C) tar sands ore from mineral resources in Canada not operated by him to any stage that is not beyond the crude oil stage or its equivalent, (iv) the processing in Canada of (A) ore, other than iron ore or tar sands ore, from mineral resources outside Canada to any stage that is not beyond the prime metal stage or its equivalent, (B) iron ore from mineral resources outside Canada to any stage that is not beyond the pellet stage or its equivalent, and (C) tar sands ore from mineral resources outside Canada to any stage that is not beyond the crude oil stage or its equivalent, (v) the processing in Canada of heavy crude oil recovered from an oil or gas well in Canada to any stage that is not beyond the crude oil stage or its equivalent, and (vi) Canadian field processing, (b.1) the total of all amounts (other than an amount included because of paragraph (b) in computing the taxpayer’s gross resource profits for the year) each of which is an amount included in computing the taxpayer’s income for the year as a rental or royalty computed by reference to the amount or value of production from a natural accumulation of petroleum or natural gas in Canada, an oil or gas well in Canada or a mineral resource in Canada, and (c) if the taxpayer owns all the issued and outstanding shares of the capital stock of a railway company throughout the year, the amount that may reasonably be considered to be the railway company’s income for its taxation year ending in the year from the transportation of such of the taxpayer’s ore as is described in clause (b)(ii)(A), (B) or (C), exceeds the aggregate of the taxpayer’s losses for the year from the sources described in paragraph (b), where the taxpayer’s incomes and losses are