5 October 1989 Income Tax Severed Letter AC74261 - Position Paper on the Taxation of Placer Mining

By services, 22 July, 2022
Official title
Position Paper on the Taxation of Placer Mining
Language
English
Document number
Citation name
AC74261
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
656631
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1989-10-05 08:00:00",
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Main text

October 5, 1989

         FROM - Resource Industries Section
                G.R. White
                957-8585
         TO - Special Audits Division
              E.H. Gauthier
              Director
              Attention: Shaukat Lakhani
         SUBJECT: Position Paper on the Taxation
                  of Placer Mining Industry
         We are writing in reply to your memorandum of August 18,
         1989, requesting that we review the above-captioned
         paper and provide you with our comments thereon.
         After a preliminary review of the paper, we noted a
         number of audit guidelines contained therein for which
         we express no opinion on herein.  Our comments which are
         limited to the technical issues which you have
         identified to us under the various headings in your paper
         are as follows:
         1. PRODUCTION IN REASONABLE COMMERCIAL QUANTITIES
         21(1)(b)
         Therefore, only expenditures incurred BEFORE a mine has
         achieved production in reasonable commercial quantities
         can qualify as CEE.
         21(1)(b)
         2.      21(1)(b)
         As provided for in paragraph 66.1(6)(a) of the Act, any
         expense that may reasonably be considered to be related
         to a mine that has come into production in reasonable
         commercial quantities cannot be considered as CEE.
         21(1)(b)
         3. INVENTORY VALUATION
         21(1)(b)
         4. PREPRODUCTION REVENUE
         21(1)(b)
         It should be stated that the Department's positions with
         respect to the issues discussed herein have not changed
         from those contained in the attached letters.
         J.T. Gauvreau
         Chief
         Resource Industries Section
         Bilingual Services and Resource
            Industries Division
         Rulings Directorate