Income Tax Considerations Affecting the Drilling Fund - A Practitioner's Viewpoint

  • Michael A. Carten
Keywords: Energy Law, Petroleum Law


The 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.