Publication 535 |
2000 Tax Year |
Exploration Costs
The costs of determining the existence, location, extent, or
quality of any mineral deposit are ordinarily capital expenses if the
costs lead to the development of a mine. You recover these costs
through depletion as the mineral is removed from the ground. However,
you can choose to deduct domestic exploration costs paid or incurred
before the development stage began (except those for oil, gas, and
geothermal wells).
How to make the choice.
You choose to deduct exploration costs by taking the deduction on
your income tax return or an amended income tax return for the tax
year you paid or incurred the costs. Your return must adequately
describe and identify each property or mine, and clearly state how
much is being deducted for each one. The choice applies to the tax
year you make this choice and all later tax years.
Partnerships.
Each partner, not the partnership, chooses whether to capitalize or
to deduct that partner's share of exploration costs.
Reduced corporate deductions for exploration costs.
A corporation (other than an S corporation) can deduct only 70% of
its domestic exploration costs. It must capitalize the remaining 30%
and amortize them over the 60-month period starting with the month the
exploration costs are paid or incurred. The 30% the corporation
capitalizes cannot be added to its basis in the property for purposes
of figuring cost depletion. However, the amount amortized is treated
as additional depreciation and is subject to recapture as ordinary
income on a disposition of the property. See Section 1250
Property under Depreciation Recapture in chapter 3 of
Publication 544.
These rules also apply to the deduction of development costs for
corporations. See Development Costs, later.
Recapture of exploration expenses.
When your mine reaches the producing stage, you must recapture any
exploration costs you chose to deduct. Use either of the following
methods.
- Method 1--Include the deducted costs in gross income
for the tax year the mine reaches the producing stage. Your choice
must be clearly indicated on the return. Increase your adjusted basis
in the mine by the amount included in income. Generally, you must
choose this recapture method by the due date (including extensions) of
your return. However, if you timely filed your return for the year
without making the choice, you can still make the choice by filing an
amended return within 6 months of the due date of the return
(excluding extensions). Make the choice on your amended return and
write "FILED PURSUANT TO SECTION 301.9100-2" on the form
where you are including the income. File the amended return at the
same address you filed the original return.
- Method 2--Do not claim any depletion deduction for the
tax year the mine reaches the producing stage and any later tax years
until the amount of depletion you would have deducted equals the
amount of deducted exploration costs.
You also must recapture deducted exploration costs if you receive a
bonus or royalty from mine property before it reaches the producing
stage. Do not claim any depletion deduction for the tax year you
receive the bonus or royalty and any later tax years, until the amount
of depletion you would have deducted equals the amount of your
deducted exploration costs.
If you dispose of the mine before your deducted exploration costs
have been fully recaptured, recapture the balance by treating all or
part of your gain as ordinary income.
Foreign exploration costs.
If you pay or incur exploration costs for a mine or other natural
deposit located outside the United States, you cannot deduct all the
costs in the current year. You can choose to include the costs (other
than for an oil, gas, or geothermal well) in the adjusted basis of the
mineral property to figure cost depletion. (Cost depletion is
discussed in chapter 10.)
If you do not make this choice, you must
deduct the costs over the 10-year period beginning with the tax year
in which you pay or incur them. These rules also apply to foreign
development costs.
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