Canada Revenue Agency Reverses Decision, Allowing CEE-Eligibility for 10,000 tonne Bulk Sample at Thor
FOR IMMEDIATE RELEASE
Taranis Resources Inc.
681 Conifer Lane
Estes Park, Colorado
80517
www.taranisresources.com
Canada Revenue Agency Reverses Decision, Allowing CEE-Eligibility for 10,000 tonne Bulk
Sample at Thor
Estes Park, Colorado, January 25, 2024 – Taranis Resources Inc. (“Taranis” or the “Company”) [TSX.V:
TRO, OTCQB: TNREF] is pleased to announce that the Canada Revenue Agency (“CRA”) has reversed
its 2021 ruling that disallowed the use of Canadian Exploration Expenses (“CEE”) treatment for certain
expenditures incurred in 2017 and 2018 relat ed to the permitting of the 10,000 tonne exploration Bulk
Sample. This ruling was made in response to the Company’s “Request for Loss Determination for the
taxation years ended December 31, 2017 and December 31, 2018” which it filed on February 1, 2022.
History of Bulk Sample Permitting at Thor
Taranis submitted a Joint Environmental and Mines Act (“JEMA”) Permit application to the government
of British Columbia on October 15, 2018. Pre-Screening began on January 15, 2019 and was completed on
September 16, 2019. On September 16, 2019, the Permit application proceeded to Technical Review.
During the Technical Review process, twenty-three (23) government reviewers provided commentary on
the application. During the Technical Review period, Taranis performed numerous studies that included
water quality baseline studies, engineering construction reports and environmental studies at an estimated
cost of almost C$1M. The Mines Act Permit was issued on June 17, 2021 after the B.C. Ombudsperson’s
Office investigated lengthy governmental delays and inconsistent policy implementation with the Permit
application.
Canda Revenue Agency (“CRA”) Audit of CEE-eligibility of Exploration 10,000 tonne Bulk Sample
In January of 2020, t he CRA informed T aranis that it would be conducting an audit of 2017-2018 CEE
expenditures. On August 30, 2021, the CRA informed Taranis that it was disallowing permitting regarding
its Bulk Sample to be eligible for CEE, because “ the expenditures are excessive for a n exploration Bulk
Sample”. Taranis was able to successfully argue that the costs for such a n exploration Bulk Sample were
mandated by the British Columbia government under the JEMA. Shortly thereafter, the CRA formulated a
new rationale and said “the Bulk Sample was not processing a Mineral Resource” because it drew on broken
ore stockpiles in the True Fissure Open Pit. Again, Taranis was able to successfully demonstrate that
stockpiles do constitute part of Mineral Resources, and therefore meet the purpose test. Finally, on January
22, 2021, the CRA issued its Final Let ter and said that “ Taranis was seeking an Optimal Method ” for
processing the stockpiled material. Taranis was not given the opportunity to comment on the CRA’s Final
Letter, and the only recourse was to file a “Request for Loss Determination ” for the taxation years ended
December 31, 2017 and 2018. Finally, on January 9, 2024, Taranis was informed that the CRA Appeals
Division had completed its review and that the 10,000 tonne Bulk Sample permitting costs were in fact CEE
eligible, thus reversing CRA’s previous position.
Engineering Site Investigation Completed
Once Taranis had received notice that the CRA was disallowing CEE treatment of certain costs relating to
the exploration 10,000 tonne Bulk Sample, Taranis discontinued spending on the venture until such time as
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a decision could be made on the CEE-Eligibility. Now that this issue has been resolved to the Company’s
satisfaction, Taranis intends on moving forward. In that regard, Taranis has submitted an engineering report
prepared by Knight Piésold to the Province of British Columbia’s Ministry of Energy, Mines and Low
Carbon Innovation as part of the documentation that is necessary prior to construction of the bulk sample
processing facility.
Comment
John Gardiner, President and CEO, states, “We have worked tirelessly to ensure that our exploration 10,000
tonne Bulk Sample was properly treated as an exploration activity for our shareholders. This is an important
step toward completing an eventual economic assessment of the Mineral Resource at Thor. Taranis had a
professional responsibility to bring th is issue to the attention of knowledgeable industry representative
groups. Consequently, we had numerous discussions with the Prospectors and Developers Association of
Canada regarding the CEE eligibility issue. Our guiding principle on this is ‘Do what's right and right will
follow.’ Exploration companies should be first and foremost concerned with undertaking safe and
environmentally sound exploration, and should not be perpetually countering misdirected permitting and
tax issues which are being weaponized by the B.C. government. In British Columbia, there is substantial
room for improvement permitting exploration projects; and making tardy or incorrect policy/regulatory
decisions has adverse consequences on capital availability to industry in the province . The industry is in
decline in British Columbia which saw a $100M drop in exploration expenditures in 2023 - a trend that is
only going to accelerate in 2024. It is ironic that although the provincial government trumpets the desire to
produce strategic metals, and assures the sector that “Once you make your investments in British Columbia,
then your investments are safe ”, reality has demonstrated that n othing could be further removed from the
reality of B.C.’s exploration/mining sector.
For additional information on Taranis or its 100% -owned Thor project in British Columbia, visit
www.taranisresources.com
Taranis currently has 94,587,027 shares issued and outstanding (109,262,027 shares on a fully -diluted
basis).
TARANIS RESOURCES INC.
Per: John J. Gardiner (P. Geo.),
President and CEO
For further information contact:
John J. Gardiner
681 Conifer Lane
Estes Park, Colorado 80517
Phone: (303) 716-5922
Cell: (720) 209-3049
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This News Release may contain forward looking statements based on assumptions and judgments of management regarding
future events or results that may prove to be inaccurate as a result of factors beyond its control, and actual results may dif fer
materially from expected results.