CRA interprets qualifying environmental trust provisions purposively

Paragraph 20(1)(ss) provides a current deduction for a contribution to a "qualifying environmental trust," e.g., a trust to secure reclamation obligations at a mine.  The related "qualifying site" definition refers to "a site in Canada that is or has been used primarily for…the operation of a mine…[or] the deposit of waste."

In granting a ruling, CRA stated that to "define the mine site narrowly, such that only the shaft is included, does not support the policy of a QET," so that the whole of the site as defined in the reclamation agreement with the Province qualified.  See also the post immediately above.

Neal Armstrong.   Summary of 2013 Ruling 2012-0463621R3 under s. 211.6(1) – qualifying site.