| 24(1) | File No. 5-7904 |
| A. Nelson | |
| (613) 957-8984 |
19(1)
May 16, 1990
Re: 24(1) Opinion Request
We are writing in reply to your letter of April 14, 1989, wherein you request our opinion concerning whether 24(1) will have a major expansion for the purposes of subparagraph (a)(ii) of Class 28, Schedule II of the Regulations to the Income Tax Act ("Class 28").
Background
24(1)
24(1)
Analysis
Class 28 includes assets situated in Canada that would otherwise be included in another class that were "acquired by the taxpayer principally for the purpose of ... and each of which ... was the subject of a major expansion after November 7, 1969 whereby the greatest designed capacity, measured in tons of input of ore, of the mill that processed the ore from the mine was not less than 25 per cent greater in the year immediately following the expansion than it was in the year immediately preceeding the expansion".
The words utilized in Class 28 clearly indicate that a major expansion is measured in terms of input of ore processed in a mill.
Position
24(1)
Yours truly,
Section ChiefResource Industries SectionBilingual Services and ResourceIndustries DivisionRulings Directorate
Principal Issue Sheet
| 24(1) | Allan Nelson |
| Resource Industries |
Issue
24(1)
23
21(1)(b)
We advised Current Amendments of the position that we were adopting, requesting them to inform Finance accordingly.
Section ChiefResource Industries SectionRulings Directorate