Principal Issues: What are the types of expenses that would normally qualify as exploration costs under paragraph (f) of the definition of "Canadian exploration expense" in subsection 66.1(6) in the context of a mining project?
Position: See attached table.
Reasons: See attached table.
February 21, 2019
| Gord Parr Director Large Business Audit Division International and Large Business Directorate International, Large Business and Investigations Branch |
Income Tax Rulings Directorate Kimberley Wharram (416) 973-3066 |
2019-079679
Mining Expenditure Review Table
Further to our discussions with Industry Specialist Services and Natural Resources Canada, I am attaching a copy of the mining expenditure review table that describes expenditures that would normally qualify as exploration costs under paragraph (f) of the definition of Canadian exploration expense (CEE) in subsection 66.1(6) of the Income Tax Act (Canada). The table is intended as a guide only. The actual treatment of a particular expense incurred by a taxpayer will depend on the facts relevant to the particular situation and, therefore, may differ from that outlined in this table.
Yours truly,
Kimberley J. Wharram
Manager, Resources Section
Reorganizations Division
Income Tax Rulings Directorate
Legislative Policy and Regulatory Affairs Branch