17 July 2018 External T.I. 2018-0747311E5 - Geothermal Energy Project -- summary under Subparagraph (d)(viii)

CRA indicated that the costs of both drilling and (except as noted below) completing exploratory wells for a geothermal project generally qualify as Canadian renewable and conservation expense (“CRCE”), whereas in the case of a production well or a (smaller diameter) exploratory well that nonetheless ends up being used for production (including small-scale heat or electricity production), the costs only of drilling qualify as CRCE whereas the costs of completing such a well would not so qualify and generally would be an addition to the Class 43.1 costs of the project.

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