16 May 1990 Ministerial Correspondence 57904 F - CCA Class 28 - Major Expansion

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ARC.

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

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