Income Tax Considerations Affecting the Drilling Fund - A Practitioner's Viewpoint
Keywords:Energy Law, Petroleum Law
AbstractThe author reviews federal income tax considerations involved in structuring drilling fund, particularly where the organizational form is the limited partnership. He discusses classification, allocation and deduction of partnership costs, including management and other fees; the use ofpartnership borrowings; factors to take into account in timing particular deductions; and the requirements for disclosure of tax consequences in drilling fund offering Practices and policies of Revenue Canada are referred to throughout the paper.
Author(s) retain original copyright in the substantive content of the titled work, subject to the following rights that are granted indefinitely:
- Author(s) grant the Alberta Law Review permission to produce, publish, disseminate, and distribute the titled work in electronic format to online database services, including, but not limited to: LexisNexis, QuickLaw, HeinOnline, and EBSCO;
- Author(s) grant the Alberta Law Review permission to post the titled work on the Alberta Law Review website and/or related websites.
- Author(s) agree that the titled work may be used for educational or instructional purposes and/or in educational or instructional materials. The author(s) acknowledge that the titled work is subject to other such "fair dealing" provisions and applicable legislation.
- Author(s) grant a limited license to those accessing the titled work from an electronic database or an Alberta Law Review website to download the titled work onto their computer and to print a copy for their own personal, non-commercial use, subject to proper attribution.
To use the journal's content elsewhere, permission must be obtained from the author(s) and the Alberta Law Review.