This isn't a case of honouring tax losses. The question is...

This isn't a case of honouring tax losses. The question is whether WR1 and Stornoway are in the same line of business. It will require professionals that regularly engage with the Canadian taxation authorities to provide advice on this and it may depend on documents that are not visible to the public.

This is not taxation advice but it would appear that:

• If in taxation documents Stornoway described their line of business as seeking to extracting economically valuable metals and minerals from Canadian (principally Quebec) soils and rocks then there is a strong case that WR1 and Stornoway are in the same line of business.

• If Stornoway described their business more narrowly as mining for diamonds, then they are clearly in a different line of business. It would be sensible for Stornoway to have defined the nature of their business widely, but whether they defined it widely enough that spodumene concentrate and diamonds are considered the same business will require professional legal and accounting advice. The starting position from the Canadian revenue service would most likely be no.

Section 111(5) is:


The footnote below on a tax utilization report by the school of public policy in the University of Calgary provides an alternative wording of the subsection above. Subsections 111(4) and 111(5) are the key.


In places like pitchbook, Stornoway used a narrower description that noted their business focus as being on Diamonds. This isn't conclusive but indictive that they may have used a narrow not wide definition elseware.

Stornoway Diamond Company Profile 2024: Valuation, Investors, Acquisition | PitchBook
"Stornoway Diamond Corp is a leading Canadian diamond exploration and producing company. Its principal business is the development of its flagship asset, the fully-owned Renard Mine, located in Quebec, Canada. The company intends to grow its business through the exploration and development of its mines. Stornoway also holds interests in a portfolio of exploration assets across Canada through owned properties and joint ventures. These properties and joint ventures include projects such as Adamantin, Qilalugaq and Pikoo."