The Queen v. Gulf Canada Resources Ltd., 96 DTC 6065 (FCA)

Pratte J.A. noted (at p. 6067) (and Linden J.A. concurred at p. 6069) that the reasonable expectation of profit doctrine had no application where...

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Pratte J.A. found (contrary to the interpretation of the minority) that the definition of "minerals" supposed that bituminous sands are included...

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Pratte J.A. noted (at p. 6067) (and Linden J.A. concurred at p. 6069) that the reasonable expectation of profit doctrine had no application where...

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Although the taxpayer (which was a participant in the Syncrude oil sands project) went on to achieve partial success on other grounds, Pratte J.A....

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The extraction by the taxpayer of bitumen from oil sands, and the transformation by it of the bitumen into crude oil, gave rise to "income or loss...

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