11 September 2007 External T.I. 2007-0227421E5 F - Investment tax Credit - Production of Slate -- summary under Mineral Resource

In finding that the harvesting of slate from a quarry likely constituted “producing industrial minerals” for purposes of s. (c)(vii) of "qualified property" in s. 127(9), rather than "extracting minerals from a mineral resource" for purposes of s. (c)(v) thereof, CRA stated:

[S]late, if mined for roofing or flooring tiles, would certainly qualify as an industrial mineral.

Furthermore, with respect to subparagraph (d)(i) of the definition of "mineral" in subsection 248(1) … experts from the Ministry of Natural Resources have advised us that the degree of metamorphism that the primary rock has undergone is unlikely to have completely erased the stratification of the deposit. Under those conditions, the deposit would therefore be excluded from the definition of "mineral" in subsection 248(1).

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