| Director General | File No. 5-1940 |
| Tax Policy Analysis Division | G.I. White |
| Energy, Mines & Resources Canada | 957-8585 |
| Room 706, 580 Booth Street | |
| Ottawa, Ontario | |
| K1A 0E4 |
Attention: Mr. Donald G. Schell Director Mining Tax Legislation Interpretation Division
October 30, 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 report on the diamond drill program of 24(1) which indicates the company was trying to determine the existence of diamondiferous kimberlite pipes. We also attach copies of the company's letter to us and copies of their correspondence with the Canadian Exploration Incentive Program. Please advise us if you require any further information.
Yours truly,
C.C. B. DarlingngDirector GeneralRulings DirectorateLegislative and Intergovernmental Affairs Branch