| 19(1) | G.R. White |
| (613) 957-8585 | |
| File No. 5-8850 |
November 28, 1989
Dear Sirs:
Re: Diamonds Deposits - Mineral Resource
We are writing in reply to your letters dated October 10 and 16, 1989, in which you requested certification that any diamond deposits discovered in kimberlite pipes as a result of an exploration program of 24(1) would qualify as a mineral resources as defined in subsection 248(1) of the Income Tax Act (the "Act").
The Minister of Energy, Mines and Resources has certified with respect to such diamond deposits that the principal mineral that would be extracted therefrom, diamonds, would be an industrial mineral contained in a non-bedded deposit.
Consequently, we are of the opinion that the diamond deposits occurring in kimberlite would qualify as a mineral resource under subparagraph (d)(i) of the definition in subsection 248(1) of the Act.
Yours truly
Chief Resource Industries SectionBilingual Services and Resource Industries DivisionRulings Directorate