Income Tax Regulations — 1104
ing income. Deemed separate properties (4.11) For the purpose of subparagraph (4.01)(b)(i), if the capital cost to a taxpayer of a depreciable property (referred to in this subsection as the “single property”) includes amounts incurred at different times, then amounts deducted under paragraph 20(1)(a) or subsection 20(16) of the Act in respect of the single property are deemed to have been deducted in respect of a separate property that is not part of the single property to the extent the deducted amounts can reasonably be considered to be in respect of amounts (a) incurred before 2025; or (b) incurred after 2024, if any portion of the single property is considered to have become available for use before the time the single property is first used for the purpose of earning income. Mining (5) For the purposes of paragraphs 1100(1)(w) to (ya.2), subsections 1101(4a) to (4h) and Classes 10, 28 and 41 to 41.2 of Schedule II, a taxpayer’s income from a mine , or any expression referring to a taxpayer’s income from a mine, includes income reasonably attributable to (a) the processing by the taxpayer of (i) ore (other than iron ore or tar sands ore) all or substantially all of which is from a mineral resource owned by the taxpayer to any stage that is not beyond the prime metal stage or its equivalent, (ii) iron ore all or substantially all of which is from a mineral resource owned by the taxpayer to any stage that is not beyond the pellet stage or its equivalent, (iii) tar sands ore all or substantially all of which is from a mineral resource owned by the taxpayer to any stage that is not beyond the crude oil stage or its equivalent, or (iv) material extracted by a well, all or substantially all of which is from a deposit of bituminous sands or oil shales owned by the taxpayer, to any stage that is not beyond the crude oil stage or its equivalent; (b) the production by the taxpayer of material from a deposit of bituminous sands or oil shales; and (c) the transportation by the taxpayer of (i) output, other than iron ore or tar sands ore, from a mineral resource owned by the taxpayer that has been processed by him to any stage that is not beyond the prime metal stage or its equivalent, (ii) iron ore from a mineral resource owned by the taxpayer that has been processed by him to any stage that is not beyond the pellet stage or its equivalent, or (iii) tar sands ore from a mineral resource owned by the taxpayer that has been processed by him to any stage that is not beyond the crude oil stage or its equivalent, to the extent that such transportation is effected through the use of property of the taxpayer that is included in Class 10 in Schedule II because of paragraph (m) thereof or that would be so included if that paragraph were read without reference to subparagraph (v) thereof and if Class 41 in Schedule II were read without the reference therein to that paragraph. (5.1) For the purposes of Classes 41 to 41.2 of Schedule II, a taxpayer’s gross revenue from a mine includes (a) revenue reasonably attributable to the processing by the taxpayer of (i) ore (other than iron ore or tar sands ore) from a mineral resource owned by the taxpayer to any stage that is not beyond the prime metal stage or its equivalent, (ii) iron ore from a mineral resource owned by the taxpayer to any stage that is not beyond the pellet stage or its equivalent, (iii) tar sands ore from a mineral resource owned by the taxpayer to any stage that is not beyond the crude oil stage or its equivalent, and (iv) material extracted by a well from a mineral resource owned by the taxpayer that is a deposit of bituminous sands or oil shales to any stage that is not beyond the crude oil stage or its equivalent; (b) the amount, if any, by which any revenue reasonably attributable to the processing by the taxpayer of (i) ore (other than iron ore or tar sands ore) from a mineral resource not owned by the taxpayer, to any stage that is not beyond the prime metal stage or its equ