24 May 2005 External T.I. 2005-0121291E5 F - Processing in Canada of ore -- summary under Paragraph 10(k)

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 indicated that the Mobile Plant should be included in Class 10(k), after having noted the correspondent’s view that it was acquired by Opco for the purpose of earning "income from a mine" as defined in Reg. 1104(6)(a).

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