Examples of CCOGPE in a sentence
In most cases the CCOGPE (Cumulative Canadian Oil and Gas Property Expense) pool is relevant only if you have an opening balance.
The CCOGPE pool will be negative if the subtractions from the pool exceed the additions to the pool.
Profound's Tax Pools on a consolidated basis were not less than $200.8 million in the aggregate as at December 31, 2008, comprised approximately as follows: $66.1 million CCEE $55.7 million CCDE $21.1 million CCOGPE $38.6 million UCC $15.1 million Non-Capital Losses $4.2 million Financing Expenses and Profound has no reason to believe that its Tax Pools on a consolidated basis were materially less on the date hereof than as set forth above.
For example, if Mr. A's CCOGPE pool had an opening balance of $25,000, the CCOGPE pool would be in a credit balance of $75,000, computed as follows: Opening Balance + Rights to Royalties - Proceeds of Disposition = Closing Balance $25,000 + $300,000 - $100,000 - $300,000 = ($75,000).
The term CCOGPE is defined in subsection 66.4(5) of the Act. In addition, the proceeds of disposition of the CRP (i.e. the rights to explore for, drill for or take the oil & gas) were subtracted from the CCOGPE pool under variable F.
If Mr. A's CCOGPE pool is negative in respect of a taxation year, the excess is deducted from his Cumulative Canadian Development Expense ("CCDE") pool under variable L.
As such, in this example, the net adjustment to the CCOGPE pool will be equal to the amount of the upfront bonus payment of $100,000. Since Mr. A has disposed of TCP, he is taxable under subsection 2(3) of the Act.
Mr. A may deduct such amounts as are relevant in computing his income from the business for the taxation year, including any amount not exceeding 10% of the balance of the CCOGPE pool existing at the end of the taxation year pursuant to subsection 66.4(2) of the Act. Under paragraph 805(a) of the Regulations, the oil & gas royalties paid to Mr. A are not taxable under Part XIII of the Act if the royalties are reasonably attributable to a business carried on by him through a PE in Canada (footnote 2) .
Since the $300,000 is both added and subtracted from the CCOGPE pool, in effect, a formal valuation of the right is not required.
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