| March 29, 1990 | |
| TO - EDMONTON DISTRICT OFFICE | FROM - HEAD OFFICE |
| Bob Kisinger | Resource Industries Section |
| Chief of Business and Basic Files | G.R. White |
| (613) 957-8585 | |
| Robert Mah | |
| Business Audit Section | File No. 7-4476 |
SUBJECT: Resource Allowance and Class 29 Classification
We are writing in reply to your memorandum dated October 27, 1989 24(1) . Your questions and our responses thereto are as follows:
(1) Are the joint venture participants entitled to claim resource allowance?
24(1)
Accordingly, we advise that the joint venture participants do not have resource profits as defined in Regulation 1204 and as a result do not meet the requirements for the deduction described in paragraph 20(1)(v.1) of the Act and Regulation 1210.
Paragraph 3 of IT-492 defines an industrial mineral as a non-metallic mineral capable of being used in industry, and the word mineral has its ordinary meaning of any chemical or compound occurring naturally as a product of organic processes.
24(1)
(2) Is the joint venture involved in processing activities to qualify the plant for inclusion under Class 29?
EMR has informed us 24(1) . In view of this statement, we believe the better view is that the joint venture is engaged in the manufacturing or processing of goods for sale and that the plant would be eligible for inclusion in Class 29.
Enclosed herewith, is a copy of EMR's letter to us for your records.
J.T. GauvreauSection ChiefResource Industries SectionBilingual Services and Resource Industries DivisionRulings Directorate