The taxpayer is owned by Canadian investors, has Canadian directors and managers, employs Canadian staff, uses Canadian resources, and has its headquarters in Canada. The taxpayer is considering the positive and negative impacts of an outer space asteroid mining venture.

The taxpayer stated that the Act requires taxpayers to pay income tax on their “worldly” income from all sources. The taxpayer interpreted “world” to refer to the domain of planet Earth. Accordingly, in the taxpayer’s view, the net smelter return of an asteroid mine earned by a Canadian corporation would not be taxable under the Act if the sale occurs at the shipping point (i.e., in outer space).

Republished with permission.

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