The results of preliminary exploration work indicated that further exploration of the “Property” was warranted – but this would require work on the Property to make it safer before geologists could perform the additional work. Would such work to make the property safe qualify under para. (f) if not for the cost of depreciable property? After noting various specific exclusions from Canadian exploration expense, CRA stated:
[T]he Canada Revenue Agency's position is to generally accept as CEE costs incurred for the purpose of ensuring the safety and protection of personnel and equipment used in activities that are directly related to exploration and activities carried out for the purpose of bringing a new mine into production in reasonable commercial quantities (other than the design and installation of production equipment) to the extent that the exceptions or exclusions noted above do not apply.