November 25, 2016
Rufus Decker
Accounting Branch Chief
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street NE
Washington, DC 20549-4628
Dear Mr. Decker:
| Re: | Taseko Mines Limited |
| Form 40-F for Fiscal Year Ended December 31, 2015 | |
| Filed March 30, 2016 | |
| File No. 001-31965 |
We acknowledge receipt of your Comment Letter dated November 22, 2016 in respect of Form 40-F filed by Taseko Mines Limited (the “Company”) for the year ended December 31, 2015. Your comments are in italics to the left below, our responses are to the right.
| SEC COMMENT | RESPONSE | ||
| General | |||
| 1. | Please amend your Form 40-F to provide thecertifications required by Rule 13a-14(b) or Rule15d-14(b) and Section 1350 of Chapter 63 of Title18 of the United States Code as exhibits to theannual report. We refer you to General InstructionB(6)(a)(2)(i) of Form 40-F for further guidance. | The Company has made the requested amendment and filed the revised Form 40-F. | |
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Exhibit 99.5 |
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Aley Project |
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Aley Mineral Resources, page 38 |
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| 2. | We note in your filing, the Aley mineral resourcesare stated below and above your economic cutoffgrade. Mineral resources must have reasonableprospects for economic extraction. We believethis means that any reportable resourceestimatesmust be delimited using an economically basedcutoff to segregate resources from mineralization.Based on the information you have disclosed, yourresource disclosure at the various cutoffs belowyour economic cutoff grade provide an estimate ofgeologically available mineralization that does notappear to be economic. Pleasetell ussupplementally the basis for disclosingresourcesat cutoffs below your economic cutoff grade. | The resources provided in Table 14 are contained within an open pit shell which has been determined on the basis of reasonable assumptions for economic extraction. The base case resource within that pit is stated at a 0.2% Nb2O5 cut-off grade. The tonnage and grade provided above and below this cut-off grade are included solely to give the reader an indication of the sensitivity of the resource to cut-off grades within that common pit. In order to avoid any future confusion the Company will not include a resource sensitivity table in our AIF/Form 40- F filings going forward. | |
| Exhibit 99.6 | |||
| Notes to Consolidated Financial Statements | |||
| 2. Basis of Preparation | |||
| 2.5 Significant Accounting Policies | |||
| (d) Exploration and evaluation, page 4 | |||
3. | Your disclosure states that expenditures areconsidered development costs and capitalized aspart of mineral properties once it is expected thatthese expenditures can be recovered by futureexploitation or sale.Please expand yourdisclosure in future filings to indicate the specificfactors you consider in determining whetherexpenditures can be recovered by futureexploitation or sale and explain how your decisionto begin capitalization of costs as developmentcosts is related to the determination of mineralresources and reserves. | The Company has noted this and will provide the expanded disclosure for future filings, commencing with the Company’s audited financial statements for the year ended December 31, 2016 and related Form 40-F annual report. |
If you require any further information on any of our responses above, please feel free to contact Stuart McDonald at 778-373-4550.
Yours truly,
TASEKO MINES LIMITED
/s/ Stuart McDonald
Stuart McDonald
Chief Financial Officer