Mineco crushes nickel ore underground in its mine. Opco, which operates a bulk ore hauling business in Canada, uses a mobile crushing plant (the Mobile Plant) to reduce the size of the ore pieces to a size suitable for processing in the processing plant (Mill) through the “Second Crushing,” with the ore being transported by truck or conveyor to the Mill. CRA stated:
[T]he revenues that Opco would earn in a particular year from the Second Crushing activity could be included in computing its GRP for that year under clause 1204(1)(b)(iii)(A) … since they could constitute revenues for the year from the processing in Canada of ore derived from mineral resources in Canada that would not be mined by Opco to any stage that is not beyond the prime metal stage or its equivalent.