Mineral Resource

Table of Contents

Cases

The Queen v. Gulf Canada Resources Ltd., 96 DTC 6065 (FCA)

Pratte J.A. found (contrary to the interpretation of the minority) that the definition of "minerals" supposed that bituminous sands are included in the meaning of the phrase "petroleum ... or related hydrocarbons".

Administrative Policy

16 June 2017 External T.I. 2016-0673551E5 - Certification of Mineral Resource

nephrite (type of jade) deposit not a mineral resource

In explaining the denial of a certification request, CRA stated:.

The Minister of Natural Resources has advised that the principal mineral, nephrite, to be extracted from the Properties is not an industrial mineral contained in non-bedded deposits as it will be used as a construction material.

16 June 2017 External T.I. 2016-0674541E5 - Mineral Certification

placer jade deposit did not qualify as a non-bedded deposit of industrial mineral or as a base or precious metal deposit

The Minister of Natural Resources had advised that the principal mineral, nephrite (a type of jade), to be extracted from the in-situ deposits on the subject property was an industrial mineral contained in non-bedded deposits, subject to certain exceptions including placer nephrite deposits. The latter were considered to fail to meet this definition. CRA then stated:

Moreover, it is our view that the placer nephrite deposits on the Property do not qualify as a mineral resource pursuant to the definition of this term in subsection 248(1) of the Act.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (f) exploring a placer jade deposit did not qualify as CEE 112

8 June 1994 External T.I. 9414625 - MINING TAILINGS

Mine tailings are not considered to be a mineral resource.

November 1991 Memorandum (Tax Window, No. 12, p. 21, ¶1564)

Where the Minister of Energy, Mines and Resources has certified that the principal mineral extracted from a particular deposit is an industrial mineral contained in a non-bedded deposit, the deposit will continue to qualify as a "mineral resource" even after being sold to a new owner.

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