quality

By services, 27 March, 2025

The taxpayer incurred various pre-feasibility expenses in relation to a large and complex gold-bearing deposit in BC including for engineering services related to the geotechnical stability of rock (relevant to any open pit slope design), modelling of costs of any mine, studies of water management control and of mine waste management and tailings impoundment, underground mine analysis and design, detailed design and operating cost estimates to assess whether the project might potentially be economically viable, geotechnical drilling services and studies regarding access roads and slurry sys

Regarding whether the test of incurring an expense “for the purpose of determining the existence, location, extent, or quality of a mineral resource” (the “CEE Purpose Test”) would generally include expenses for determining the economic feasibility of a deposit, such as expenses for preparing pre-feasibility or feasibility studies (including expenses for determining the cut-off grade of the deposit), market studies or studies for determining the anticipated long-term price of a mineral, based on an expansive interpretation of the word “quality,” CRA noted: