Income Tax Regulations — (a)
resource activity of a taxpayer means (a) the production by the taxpayer of petroleum, natural gas or related hydrocarbons or sulphur from (i) an oil or gas well in Canada, or (ii) a natural accumulation (other than a mineral resource) of petroleum or natural gas in Canada, (b) the production and processing in Canada by the taxpayer or the processing in Canada by the taxpayer of (i) ore (other than iron ore or tar sands ore) from a mineral resource in Canada to any stage that is not beyond the prime metal stage or its equivalent, (ii) iron ore from a mineral resource in Canada to any stage that is not beyond the pellet stage or its equivalent, and (iii) tar sands ore from a mineral resource in Canada to any stage that is not beyond the crude oil stage or its equivalent, (c) the processing in Canada by the taxpayer 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, (c.1) Canadian field processing carried on by the taxpayer, (d) the processing in Canada by the taxpayer of (i) ore (other than iron ore or tar sands ore) from a mineral resource outside Canada to any stage that is not beyond the prime metal stage or its equivalent, (ii) iron ore from a mineral resource outside Canada to any stage that is not beyond the pellet stage or its equivalent, and (iii) tar sands ore from a mineral resource outside Canada to any stage that is not beyond the crude oil stage or its equivalent, or (e) the ownership by the taxpayer of a right to 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, for the purposes of this definition, (f) the production of a substance by a taxpayer includes exploration and development activities of the taxpayer with respect to the substance, whether or not extraction of the substance has begun or will ever begin, (g) the production or the processing, or the production and processing, of a substance by a taxpayer includes activities performed by the taxpayer that are ancillary to, or in support of, the production or the processing, or the production and processing, of that substance by the taxpayer, (h) the production or processing of a substance by a taxpayer includes an activity (including the ownership of property) that is undertaken before the extraction of the substance and that is undertaken for the purpose of extracting or processing the substance, (i) the production or the processing, or the production and processing, of a substance by a taxpayer includes activities that the taxpayer undertakes as a consequence of the production or the processing, or the production and processing, of that substance, whether or not the production, the processing or the production and processing of the substance has ceased, and (j) notwithstanding paragraphs (a) to (i), the production, the processing or the production and processing of a substance does not include any activity of a taxpayer that is part of a source described in paragraph 1204(1)(b), where (i) the activity (A) is the transporting, transmitting or processing (other than processing described in subparagraph (b)(iii), paragraph (c) or (c.1) or subparagraph (d)(iii)) of petroleum, natural gas or related hydrocarbons or of sulphur, or (B) can reasonably be attributed to a service rendered by the taxpayer, and (ii) revenues derived from the activity are not taken into account in computing the taxpayer’s gross resource profits; ( activité extractive )