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T-2132-78
Midwest Oil Production, Ltd. (Plaintiff)
v.
The Queen (Defendant)
Trial Division, Mahoney J.—Calgary, January 11; Ottawa, January 28, 1982.
Income tax — Income calculation — Appeal from 1974 and 1975 assessments — All crude oil was delivered to the Alberta Petroleum Marketing Commission for purchase — Plaintiff applied drilling incentive credits in satisfaction of natural gas royalties payable to Alberta — Whether the royalty share of crude oil delivered in kind to the Commission is an amount receivable within s. 12(1)(o) of the Income Tax Act — Whether the amount required to be included in income in respect of natural gas royalties by s. 12(1)(o) is the actual amount paid, or that amount plus the drilling incentive credits applied to reduce the amount otherwise owing — Whether s. 12(1)(o) is ultra vires — Whether the plaintiff is estopped from raising an issue for the first time in this Court — Action dismissed — Income Tax Act, S.C. 1970-71-72, c. 63, ss. 12(1)(o), 165(1), 172(2), 175(3), 248(1) — The Mines and Minerals Act, R.S.A. 1970, c. 238, ss. 31(1),(2),(4), 121(1), 142(1),(2), 170.1(1) — The Petroleum Marketing Act, S.A. 1973, c. 96, ss. 7(1), 15(1), 17, 18(1) — Exploratory Drilling Incentive Regulations, 1974, Alta. Reg. 18174, s. 10 — The British North America Act, 1867, 30 & 31 Vict., c. 3 (U.K.) IR.S.C. 1970, Appendix II, No. 5], s. 125.
The plaintiff appeals its 1974 and 1975 assessments. Para graph 12(1)(o) of the Income Tax Act requires a taxpayer to include in his taxable income any amount that became receiv able in the year by virtue of an obligation imposed by statute as a royalty or an equivalent amount in relation to the production in Canada of petroleum from an oil well situated on property in Canada from which the taxpayer had, at the time of such production, a right to take or remove petroleum. Effective December 1, 1974 all crude oil was required to be delivered at the custody transfer meter to the Alberta Petroleum Marketing Commission (hereinafter APMC), which would purchase the producer's share of crude oil and eventually would pay the producer for it. The plaintiff argued that no amount thereafter became receivable by Alberta as a royalty. The question there fore is whether the royalty share of crude oil, or its value, of Alberta delivered in kind by the plaintiff to the APMC after December 1, 1974 is an amount receivable within the contem plation of paragraph 12(1)(o). The plaintiff earned drilling incentive credits under Alberta's program of incentives for the drilling of wildcat wells. These credits could be applied in satisfaction of obligations including natural gas royalties. The Minister assessed the plaintiff on the basis that the natural gas royalties receivable by Alberta included the actual amount paid plus such credits. The plaintiff argued that the natural gas
royalties receivable by Alberta were reduced by the amounts of the credits applied. The second issue is whether the amount required by paragraph 12(1)(o) to be included in the plaintiff's income in respect of natural gas royalties is the actual amount paid to Alberta, or that amount plus the amount of drilling incentive credits applied to reduce the amount which would otherwise have been required to be paid. The third question is whether paragraph 12(1)(o) is ultra vires in light of section 125 of The British North America Act, 1867 which prohibits taxation of Crown lands. The last question is whether the plaintiff is estopped from raising an issue because it was not raised in its notices of objection.
Held, the action is dismissed. The amount receivable by Alberta as a royalty is the measure of the tax levied on the taxpayer, but it is the taxpayer, not the royalty, and not Alberta, that is taxed. An appeal to the Federal Court from the Tax Review Board is a trial de novo. A taxpayer cannot be estopped from raising any issue it wishes in an appeal to the Federal Court under subsection 172(2) of the Income Tax Act solely because an issue is raised for the first time by the pleadings. As in any action, the issues are those defined by the pleadings. The assessments based on paragraph 12(1)(o) were correct. "Receivable" in its ordinary meaning has nothing to do with a change in ownership or title; it has to do with a change in custody or possession. While it is impossible, prior to delivery of the crude oil to the APMC, and perhaps after as well, to point to a particular unit of crude oil and identify it as Alberta's royalty share, it remains that the royalty share exists, in fact, from the moment it is reduced to the lessee's possession at the well-head. Subsection 170.1(1) of The Mines and Min erals Act of Alberta requires that the royalty share be delivered to the APMC and paragraph 15(1)(a) of The Petroleum Marketing Act requires that the APMC accept delivery. Prior to such delivery, Alberta's royalty share is, in the ordinary meaning of the word, "receivable" by the APMC. The value of that share is an amount, within the clear contemplation of paragraph 12(1)(o) to be included in the lessee's income. Section 10 of the Exploratory Drilling Incentive Regulations, 1974 provides that the drilling incentive credits "may be applied in satisfaction of moneys payable" by the plaintiff with respect to natural gas royalties, among other things. The credits did not reduce the amount receivable in 1974 and 1975 by Alberta as a royalty in relation to the production of natural gas by the plaintiff; they were merely available, at its option, to be applied in partial satisfaction of that amount. They were so applied.
Phillips v. The Corporation of the City of Sault Ste. Marie [ 1954] S.C.R. 404, applied. Goldman v. Minister of
National Revenue [1951] Ex.C.R. 274, applied. Spence v. Minister of National Revenue 64 DTC 651, discussed. Rosenberg v. Minister of National Revenue 68 DTC 830, discussed.
INCOME tax appeal. COUNSEL:
John M. Roland, Q.C. and Brian G. Morgan for plaintiff.
T. B. Smith, Q.C. and C. T. A. MacNab for defendant.
SOLICITORS:
Osler, Hoskin & Harcourt, Toronto, for plaintiff.
Deputy Attorney General of Canada for defendant.
The following are the reasons for judgment rendered in English by
MAHONEY J.: This appeal is from the assess ments of the plaintiff's income tax returns for the years ended December 31, 1974 and 1975. It is concerned with paragraph 12(1)(o) of the Income Tax Act, R.S.C. 1952, c. 148, as amended by S.C. 1970-71-72, c. 63, s. 1, as that provision applied during the period November 18, 1974 to May 25, 1976.'
12. (1) There shall be included in computing the income of a taxpayer for a taxation year as income from a business or property such of the following amounts as are applicable:
(o) any amount (other than an amount referred to in para graph 18(1)(m), paid or payable by the taxpayer, or a prescribed amount) that became receivable in the year by virtue of an obligation imposed by statute or a contractual obligation substituted for an obligation imposed by statute by
(i) Her Majesty in right of Canada or a province,
(ii) an agent of Her Majesty in right of Canada or a province, or
(iii) a corporation, commission or association that is con trolled, directly or indirectly in any manner whatever, by Her Majesty in right of Canada or a province or by an agent of Her Majesty in right of Canada or a province
as a royalty or an equivalent amount, tax (other than a tax or portion thereof that may reasonably be considered to be a municipal or school tax levied for the purpose of providing services in the immediate area of the property of the taxpay-
' S.C. 1974-75-76, c. 26, s. 4(2) as amended by S.C. 1977- 78, c. 1, s. 5(1).
er), rental, bonus, levy or otherwise or as an amount, how ever described, that may reasonably be regarded as being in lieu of a royalty or an equivalent amount, tax, rental, bonus, levy or other amount (whether such royalty or equivalent amount, tax, rental, bonus, levy or other amount is receivable pursuant to any other Act or a contract) that may reasonably be regarded as being in relation to
(iv) the acquisition, development or ownership by a tax payer of a Canadian resource property or a property that would have been a Canadian resource property if it had been acquired after 1971, or
(v) the production in Canada of
(A) petroleum, natural gas or related hydrocarbons, or
(B) metal or industrial minerals to any stage that is not beyond the prime metal stage or its equivalent
from an oil or gas well or mineral resource situated on property in Canada from which the taxpayer had, at the time of such production, a right to take or remove petroleum, natural gas or related hydrocarbons or a right to take or remove metal or industrial minerals.
Subsection 248(1), with an immaterial exception, defines "amount" as "money, rights or things expressed in terms of the amount of money or the value in terms of money of the right or thing ...".
The principal issues are:
1. Whether the royalty share of crude oil, or its value, of Her Majesty in right of the Province of Alberta (hereinafter "Alberta") delivered in kind by the plaintiff to the Alberta Petroleum Marketing Commission (hereinafter "APMC") after December 1, 1974, is an amount within the contemplation of paragraph 12(1)(o), and
2. Whether the amount required by paragraph 12(1) (o) to be included in the plaintiff's income in respect of natural gas royalties is the actual amount paid Alberta or that amount plus the amount of Drilling Incentive Credits (herein- after "DIC's") applied to reduce the amount which would otherwise have been required to be paid.
I shall refer to these as the crude oil and natural gas royalty issues respectively. In addition to them, the plaintiff raised at the trial, although it had not pleaded, the constitutional validity of paragraph 12(1)(o) and the defendant pleaded that the plain tiff is estopped from raising the crude oil royalty issue inasmuch as it was not raised in its notices of objection. It is convenient to deal with these mat ters first.
The challenge to the constitutional validity of paragraph 12(1)(o) is based on section 125 of The British North America Act, 1867. 2
125. No Lands or Property belonging to Canada or any Province shall be liable to Taxation.
In Phillips v. The Corporation of the City of Sault Ste. Marie,' a provincial tax on the tenant of land belonging to the Crown was considered by the Supreme Court of Canada. The appellants, who fell within the extended meaning of "tenant", were required to reside on land owned by Her Majesty in right of Canada. Taschereau J., as he then was, at page 407, in delivering the Court's judgment, said:
There can be no doubt that under s. 32(1), the assessor places a value on Crown property for tax purposes, but the person assessed in respect of the land is not the Crown but the "tenant" who is the one who pays the tax. The value of the land is the measure of the tax, but the Act does not make the land liable to taxation and, therefore, does not conflict with s. 125 of the B.N.A. Act.
Here, the amount receivable by Alberta as a royal ty is the measure of the tax levied on the taxpayer but it is the taxpayer, not the royalty, and not Alberta, that is taxed.
The estoppel pleaded arises out of the fact that, in filing its tax returns, the plaintiff did report the amounts subject of the crude oil royalty issue as taxable income. It also reported natural gas royal ty as required by paragraph 12(1)(o) less the
2 30 & 31 Vict., c. 3 (U.K.) [R.S.C. 1970, Appendix II, No. 5].
3 [1954] S.C.R. 404.
amount of the DIC's. That deduction was the only issue raised in the notices of objection put in issue in this appeal. The crude oil royalty issue was raised for the first time by the statement of claim herein. The defendant readily admits that, had the crude oil royalty issue been raised in the returns, or by the notices of objection, the position taken would have been identical to that it now urges on the Court.
The Act provides:
165. (1) A taxpayer who objects to an assessment under this Part may, within 90 days from the day of mailing of the notice of assessment, serve on the Minister a notice of objection in duplicate in prescribed form setting out the reasons for the
• objection and all relevant facts.
172....
(2) Where a taxpayer has served a notice of objection under section 165, he may, in place of appealing to the Tax Review Board under section 169, appeal to the Federal Court of Canada at a time when, under section 169, he could have appealed to the Tax Review Board.
Section 169 prescribes an identical condition precedent to the right to appeal to the Tax Review Board and there are a number of decisions by that tribunal to the effect that it has no jurisdiction to hear an appeal on an issue not raised in the notice of objection. For example, and it is extreme, in Spence v. M.N.R., 4 the issue raised in the notice of objection was whether a company of which he was a shareholder had conferred a benefit on a taxpay er by paying the amount of a settlement of a damage action against him as well as the inciden tal legal expenses. The taxpayer sought, before the Board, to claim as a deduction from income cer tain alleged farm losses which he had not claimed in his original return and in respect of which he had sought to file an amended return only after his original return had been assessed and the appeal taken. Another example, certainly less extreme, is
4 64 DTC 651.
Rosenberg v. M.N.R., 5 where the Minister had disallowed the taxpayer's deduction of a $3,550 loss on a loan to a company of which he was a shareholder and also disallowed the deduction of $2,450 he had paid under his guarantee of the company's bank loan. The taxpayer dealt only with the $3,550 item in his notice of objection and the Board refused, for want of jurisdiction, to hear him on the $2,450 item.
This Court appears not to have dealt with this question directly. In Goldman v. M.N.R., 6 Thor- son P. was concerned with whether an appeal to the Exchequer Court from a decision of the Income Tax Appeal Board was a trial de novo. After a lengthy review of the legislation then in effect and that which it had replaced, he concluded:
All these considerations lead to the conclusion that the appeal to this Court from a decision of the Income Tax Appeal Board, whether by the taxpayer or by the Minister, is a trial de novo of the issues involved, that the parties are not restricted to the issues either of fact or of law that were before the Board but are free to raise whatever issues they wish even if different from those raised before the Board and that it is the duty of the Court to hear and determine such issues without regard to the proceedings before the Board and without being affected by any findings made by it.
The Supreme Court of Canada, in dismissing an appeal from that judgment, did not deal with that particular issue.' The relevant provisions of the Act have since been extensively amended; how ever, the conclusion that an appeal to this Court from a decision of the Tax Review Board is a trial de novo remains valid. That being so, I do not see that this Court can be without jurisdiction to deal with an issue not raised in the notice of objection when the appeal is brought directly to the Court
5 68 DTC 830.
6 [1951] Ex.C.R. 274 at p. 281.
7 [1953] S.C.R. 211.
under subsection 172(2).
I do not think that a taxpayer can be estopped, in any technical sense of that term, from raising any issue it wishes in an appeal to this Court under subsection 172(2) of the Act only because the issue was not raised in its notice of objection or, if applicable, before the Tax Review Board. It is to be emphasized that it is the Minister's assessment, not his reasons for it, that is the subject-matter of the appeal. Section 175 of the Act provides the methods by which an appeal shall be instituted in this Court and further, that
175....
(3) An appeal instituted under this section shall be deemed to be an action in the Federal Court to which the Federal Court Act and the Federal Court Rules applicable to an ordinary action apply, except ....
None of the exceptions has any relevance to this issue. As in any action, the issues which the Court must deal with are those defined by the pleadings regardless of what has gone before. That is not to say that an estoppel could not be successfully pleaded on behalf of the fisc but the plea cannot be sustained solely on the basis that an issue is raised for the first time by the pleadings in this Court.
A good deal of the time taken by the trial was devoted to evidence of a background nature. It is not necessary to deal with much of it. It is suffi cient to start at the point at which conventionally- produced petroleum and natural gas, owned in situ by Alberta, reaches the surface. I shall deal first with the crude oil royalty issue.
A typical production situation, at least in so far as the plaintiff was concerned, may be described in the following terms. What rises, or is pumped, to the surface in an oil well is a mixture of oil, gas and water. The volume of that mixture is metered at the well-head and the mixture is pumped to a battery which receives like mixtures from other, variously owned, wells. The battery is subject of a contractual arrangement among all interested pro-
ducers which, inter alia, designates one of them its operator. The production of each contributing well is tested periodically to determine its composition. The production of all of the wells becomes mixed in processing at the battery which separates the water, gas and oil. The crude oil flows through storage tanks to the pipeline of a common carrier. A custody transfer meter at the point of delivery to the common carrier measures the quantity of crude oil. It is at this point that title to the crude oil passes to its purchaser, price is fixed by the APMC and the quantity to be paid for is deter mined. Likewise, it is at this point that the quanti ty of Alberta's royalty share is fixed. Monthly allocation of the crude oil produced, including the royalty share, back to individual wells and their owners, involves mathematical calculations taking account of each well's gross production and its composition as determined by tests during the month. Without getting into lengthy and complex details, it is enough to recognize that the battery operator is constituted the agent of all its pro ducers to receive and distribute their payments and to carry out some of their obligations includ ing delivery to the APMC of Alberta's royalty share.
Prior to December 1974, all of the crude oil, including Alberta's royalty share, was sold by the producer to the purchaser at the custody transfer meter and the producer was required to pay Alber- ta the price received by it attributable to the royalty share. Effective at 7:00 a.m., December 1, 1974, all crude oil was required to be delivered at the custody transfer meter to the APMC. The APMC purchases the producer's share of the crude oil at that point and, in due course pays the producer for it. The plaintiff's position is that, upon the advent of this new regime, no amount thereafter became receivable by Alberta as a roy alty or equivalent amount and that the value of Alberta's royalty share no longer fell within para graph 12(1)(o).
The plaintiff's rights and obligations are defined by provincial legislation and by the leases entered into with Alberta pursuant to that legislation. There are some differences in the forms of lease executed from time to time; however, the varia tions appear immaterial to the issue here. The material portion of one of the leases in evidence, Exhibit 10, reads:
NOW THEREFORE THIS INDENTURE WITNESSETH that in consideration of the rents and royalties hereafter provided ... Her Majesty hereby grants unto the lessee ... the exclusive right to explore for, work, win and recover petroleum and natural gas within and under ... together with the right to dispose of the petroleum and natural gas recovered.
... rendering and paying therefor unto Her Majesty a royalty on all petroleum and natural gas obtained from the location and on all substances obtained therefrom, at such rate or rates as are now or may hereafter from time to time be prescribed by the Lieutenant Governor in Council, such royalty to be free and clear of and from all deductions whatsoever. The maximum royalty payable on the petroleum and natural gas ... shall not exceed one-sixth of the production from the location.
The last sentence is material only because of the word "payable" in it. It has been abrogated by legislation. Clause 5 of the lessee's covenants and clause 12 of the mutual covenants are similarly material and provide, in part, that:
5. The lessee shall well and truly pay or caused to be paid ... the rent and royalty payable under this lease.....
12. If and whenever the rent or royalty hereby reserved, or any part thereof, is in arrears and unpaid ....
The lease is, by definition, an agreement under the terms of The Mines and Minerals Act, 8 and petroleum, oil and natural gas are, by definition, minerals. The Act provides, inter alia,
31. (1) A royalty is reserved to the Crown in right of Alberta on the mineral that may be won, worked, recovered or obtained pursuant to any agreement or certificate of record made or entered into under this Act.
(2) The royalty to be computed, levied and collected on the mineral won, worked, recovered or obtained pursuant to any agreement or certificate of record made or entered into under this Act, the former Act or The Provincial Lands Act shall be the royalty prescribed from time to time by the Lieutenant Governor in Council.
8 R.S.A. 1970, c. 238, as amended.
(4) A royalty reserved to the Crown in right of Alberta on a mineral
(a) is payable in kind except as otherwise provided by this Act or any order of the Lieutenant Governor in Council, and
(b) is payable on the mineral when and where obtained, recovered or produced.
121. (1) A lease grants the right to the petroleum and natural gas that are the property of the Crown in the location subject to any exceptions expressed in the lease.
142. (1) The petroleum and natural gas obtained from any location acquired under this Part is subject to the payment to the Crown of such royalty thereon as may from time to time be prescribed by the Lieutenant Governor in Council.
(2) The royalty shall be collected in such manner as may be prescribed by the Minister.
170.1 (1) Every agreement to which this section applies is subject to the condition that the Crown's royalty share of the petroleum recovered pursuant to the agreement shall be deliv ered to the Alberta Petroleum Marketing Commission incorpo rated under The Petroleum Marketing Act.
Paragraph (a) was added to subsection 31(4) and section 170.1 was enacted by S.A. 1973, c. 94. All leases material to this action were made subject of section 170.1, effective March 1, 1974, by Alberta Regulation 15/74. The 1973 amendments to The Mines and Minerals Act were part of a legislative scheme that included enactment of The Petroleum Marketing Act 9 whereby the APMC was created as a body corporate. That Act provides, inter alia,
7. (1) The Commission is for all purposes an agent of the Crown in right of Alberta and its powers may be exercised only as an agent of the Crown in right of Alberta.
15. (1) The Commission
(a) shall accept delivery within Alberta of the Crown's royalty share of the petroleum recovered pursuant to an agreement and required to be delivered to it by section 170.1 of The Mines and Minerals Act, and
(b) subject to subsection (2), shall sell within Alberta the Crown's royalty share of petroleum at a price that is in the public interest of Alberta.
17. The Commission shall pay the proceeds of sales of petroleum by it under this Part to the Provincial Treasurer for
9 S.A. 1973, c. 96.
deposit in the General Revenue Fund in accordance with the directions of the Provincial Treasurer.
18. (1) The delivery to the Commission of the Crown's royalty share of petroleum recovered pursuant to an agreement operates to discharge the lessee with respect to his liability to pay that royalty to the Crown in right of Alberta ....
The Petroleum Marketing Act was proclaimed and the APMC was constituted on January 15, 1974. It became operative March 1. Without necessarily accepting its legal conclusions, the APMC's memorandum to producers, triggered by its receipt of T-5 information slips early in 1975, accurately describes the crude oil royalty regimes in effect during 1974.
a) As regards production from Alberta Crown Lands during the period commencing March 1, 1974 and ending Novem- ber 30, 1974, the Commission took delivery of the Crown royalty share of petroleum in kind. The lessees delivered this Crown royalty share of petroleum to crude oil purchasers for sale by the Commission. The lessees received from the crude oil purchasers the proceeds of sale of the Crown royalty share. The receipt of these proceeds was on behalf of the Commission. Under this procedure there is no payment by the lessee to the Commission of either "royalties from Canadian sources" or "other income from Canadian sources".
b) As regards production of petroleum from Alberta Crown Lands for the month of December 1974 and following, the Commission took delivery of the Crown royalty share of petroleum at the battery and received payment for the proceeds of sale of the Crown royalty share directly from the crude oil purchasers. Again under this procedure there is no payment by the lessee to the Commission of either "royalties from Canadian sources" or "other income from Canadian sources".
The regime described in paragraph b) prevailed throughout 1975. The legal basis for that regime is established by the provincial legislation, recited above.
Stripped of verbiage inapplicable to the crude oil royalty issue, paragraph 12(1)(o) requires a taxpayer to include in his taxable income
... any amount that became receivable in the year by virtue of an obligation imposed by statute by an agent of [Alberta] as a royalty or an equivalent amount in relation to the production in Canada of petroleum from an oil well situated on property in Canada from which the taxpayer had, at the time of such production, a right to take or remove petroleum.
The value of Alberta's royalty share is readily expressed in terms of money. Indeed, it is routinely expressed that way. Alberta's royalty share is an "amount" within the extended definition of that term under the Income Tax Act. The only serious question is whether, under the regime in effect from December 1, 1974, through 1975, it was an " amount receivable". If it was an amount receiv able, it was certainly an amount receivable by Alberta's agent, the APMC, that fell squarely within the prescription of the balance of paragraph 12(1)(o). It is unnecessary to decide whether the obligation is imposed by statute or is a contractual obligation substituted for a statutory obligation; it is clearly one or the other or both.
All of the crude oil, including Alberta's royalty share, belongs to Alberta in its subterranean situa tion. At some point in the production process, ownership of an undivided share of that crude oil passes to its producer. I accept that ownership of the royalty share remains with Alberta through out, until sold by the APMC. Any alternative, for example that the producer obtains title to all of the crude oil at some point in the process and that title to the royalty share passes to Alberta upon its delivery to the APMC, does not strengthen the plaintiff's case.
Nothing, in my view, turns on the term "receiv- able" being the antonym of "payable" in common accounting terminology nor the related conclusion invited by the use of the word "payable" and variations thereon in the leases and the provincial legislation. This issue is not concerned with gener ally accepted accounting principles but with the interpretation of a statute. While it may be that no royalty became payable in respect of crude oil under the regime imposed December 1, 1974, that is not the issue and I will leave to someone else the possibly neat question whether an obligation to deliver to another his own property gives rise to an amount being payable. The issue here is whether
such an obligation gave rise to an amount being receivable by Alberta or its agent, the APMC.
"Receivable" is not defined by the Income Tax Act. It is not a technical term. Its primary mean ing, according to The Shorter Oxford English Dictionary, is "capable of being received", while that of "receive" is "to take in one's hand, or into one's possession (something held out or offered by another); to take delivery of (a thing) from another, either for oneself or for a third party". "Receivable", in its ordinary meaning, has nothing to do with a change in ownership or title; it has to do with a change in custody or possession.
While it is impossible, prior to delivery of the crude oil to the APMC, and perhaps after as well, to point to a particular unit of crude oil, either after separation or while still in mixture with gas and water, and identify it as a unit of Alberta's royalty share, it remains that the royalty share exists, in fact, from the moment it is reduced to the lessee's possession at the well-head. Subsection 170.1(1) of The Mines and Minerals Act requires that the royalty share be delivered to the APMC and paragraph 15(1)(a) of The Petroleum Mar keting Act requires that the APMC accept deliv ery. Prior to such delivery, Alberta's royalty share is, in the ordinary meaning of the word, "receiv- able" by the APMC. The value of that share is an amount, within the clear contemplation of para graph 12(1)(o) of the Income Tax Act, to be included in a lessee's income. The value ascribed to the share in the assessments subject of this appeal is not in issue.
Turning to the natural gas royalty issue, effec tive in 1972, Alberta established a scheme of incentives to the drilling of wildcat wells. The plaintiff earned credits under that program. Amounts credited to it could not be withdrawn in cash but were available to be applied in satisfac tion of prescribed obligations including natural gas royalties. The plaintiff paid natural gas royalties of $22,170.97 in 1974, and $50,122.47 in 1975, and
included those amounts in its taxable income pur suant to paragraph 12(1)(o). The plaintiff also requested Alberta to apply DIC's totalling $3,138.56 in 1974, and $24,122.44 in 1975, against natural gas royalties. The Minister assessed on the basis of natural gas royalties receivable by Alberta in the amounts of $25,309.53 in 1974, and $74,234.91 in 1975. I note a $10 discrepancy in the 1975 addition.
Regulations '° in effect during 1974 and 1975, provided:
10. Credit established pursuant to section 8, upon the written request of the holder thereof, and subject to procedures estab lished by the Department, may be applied in satisfaction of
(a) moneys payable by him with respect to any applications and dispositions made under Part 5 of The Mines and Minerals Act,
(b) moneys payable by him pursuant to section 40 of The Mines and Minerals Act, or
(c) taxes levied under The Freehold Mineral Taxation Act,
and becoming due and payable between January 1, 1974 and December 31, 1979.
Moneys payable to Alberta on the sale by a lessee of Alberta's royalty share of natural gas fall within paragraph (a).
In pleading, the plaintiff alleged that the natural gas royalties receivable by Alberta were reduced by the amounts of the DIC's applied. It argued, correctly, that it never had a right to receive the amount of the DIC's in money but was entitled only to apply it as section 10 prescribed. The argument then was that the DIC's were, therefore, not a debt or sum owing by the Crown to the plaintiff and, thus, could not constitute a set-off against the royalty obligation as might be the case with mutual debts. It follows, presumably, that, since the DIC's could not be a set-off against the royalty, their application to that obligation must have had the effect of reducing the obligation in a way that, to the extent of the reduction, the obliga-
1 0 Exploratory Drilling Incentive Regulations, 1974, Alta. Reg. 18/74.
tion is to be deemed never to have existed rather than to have been partly satisfied.
I hope I am not misrepresenting the position but, I must admit, I find it hard to understand. In any event, the whole argument ignores completely the plain words of section 10. The DIC's "may be applied in satisfaction of moneys payable" by the plaintiff with respect to natural gas royalties, among other things. The DIC's did not reduce the amount receivable in 1974 and 1975 by Alberta as a royalty in relation to the production of natural gas by the plaintiff; they were merely available, at its option, to be applied in partial satisfaction of that amount. They were so applied.
The plaintiff also argued that, in any event, because the actual amount of natural gas royalty receivable by Alberta in respect of a given calen dar year cannot be ascertained until the following year, the amounts assessed to the plaintiff for 1974 and 1975 should have been assessed for 1975 and 1976 respectively. This issue was not raised by the pleadings and I do not, therefore, propose to deal with it. It is an issue which, if properly raised, would likely have been subject of evidence and not just argument as was the constitutional issue.
Having found that the assessments based on the application of paragraph 12(1)(o) were correct, it is not necessary to deal with the defendant's alter native pleading of paragraph 18(1)(m) and subsec tion 69(6) of the Income Tax Act. The action is dismissed with costs.
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