- Parties: The appellant was Potash Corporation of Saskatchewan Inc. The respondent was His Majesty the King.

- Subject Matter: The Tax Court of Canada found that the appellant was not entitled to deduct base payments paid to the province of Saskatchewan under the Mineral Taxation Act, 1983 (MTA) and under the Potash Production Tax Schedule to the MTA. On appeal, the issue was whether the appellant was entitled to deduct the base payments when computing its income for the purposes of the Income Tax Act, 1985 for its taxation years 1999-2002.

- Ruling: The appeal court ruled in the respondent’s favour and dismissed the appeal with costs. The base payments were not expenditures made or incurred for the purpose of gaining or producing income through making any sale of potash, the appellate court said. Instead, the base payments were made or incurred as a result or consequence of the appellant gaining or producing income by selling potash, the appeal court explained. Since s. 18(1)(a) of the Act resulted in a denial of the deduction in issue, the appeal court found that it did not need to consider whether s. 18(1)(m) of the Act would also have denied such deduction.

- Date: The hearing was set on Nov. 23, 2023. The court released its decision on Feb. 27, 2024.

- Venue: This was a federal case before the Federal Court of Appeal.

- Amount: No financial award was specified.