| Director General | |
| Tax Policy Analysis Division | |
| Energy, Mines & Resources Canada | File No. 5-8850 |
| Room 706, 580 Booth Street | G.R. White |
| Ottawa Ontario | 957-8585 |
| K1A 0E4 |
Attention: Mr. Donald G. Shell DirectorMining Tax Legislation Interpretation Division
October 19, 1989
Dear Sirs:
Re: 24(1) Mineral Resource Subsection 248(1) of the Income Tax Act
We are writing to request your certification that diamond deposits occurring in kimberlite pipes is a mineral resource as that term is defined under subparagraph (d)(i) of the definition in subsection 248(1) of the Income Tax Act.
Attached is a letter and a fax from the 24(1) legal representative stating that the company is exploring for diamonds in kimberlite pipes near 24(1) The certification is required to secure the release of a CEIP grant.
We note your reply dated November 20, 1987, to a similar request from 24(1)
Yours truly,
Director General Rulings DirectorateLegislative and IntergovernmentalAffairs Branch