Depletion instead of ordinary cost recovery
The cost of the deposit is recovered through cost or percentage depletion, with rates set by mineral.
Industry tax guide
Tax planning for exploration, development and extraction, each with its own rules.

Mining companies spend years exploring and developing a site before production, then extract a resource that is used up as they sell it. Equipment is heavy and expensive, and the end of each project brings reclamation costs.
The tax code treats each phase differently, and the choices made early, such as how exploration costs are handled, affect deductions for the life of the mine.
Compared with a general business
The cost of the deposit is recovered through cost or percentage depletion, with rates set by mineral.
Section 617 exploration and Section 616 development costs have their own deduct-or-defer elections and recapture.
Reclamation and closing costs have special timing rules and, in some cases, reserve elections.
Most mining states levy severance taxes on extracted minerals, separate from income tax.
The rules in detail
Mine operators recover the cost of the mineral deposit through depletion, taking the larger of cost depletion or percentage depletion. Percentage depletion uses a set rate for each mineral, applied to gross income from the property and limited by taxable income.
Costs to find the extent and quality of a deposit can be deducted as paid under Section 617, then recaptured when the mine reaches production, or capitalized. The choice affects both current deductions and later depletion.
Once a deposit is shown to exist in commercial quantity, development costs such as shafts and access roads can be deducted as paid under Section 616 or deferred and deducted as the minerals are sold.
Planning moves
Calculated every year for each property.
Section 617 deductions are timed against current income and later recapture.
Section 616 deductions accelerate recovery of shafts and roads.
Heavy equipment acquired after January 19, 2025 qualifies at 100%.
Reclamation reserves and timing are reviewed with your obligations.
Severance tax payments are recorded so they reduce income tax where allowed.
Working with OICPA
We model deducting versus capitalizing for each project before the return is filed.
Business Tax AdvisoryHaul trucks, processing equipment and conveyors with 100% bonus depreciation for property acquired after January 19, 2025.
Business Tax PlanningCosts tracked by exploration, development and production phase so the tax treatment follows the records.
Management Reporting & KPI DashboardsJoint ventures, royalty entities and state filings kept current.
Entity Formation & ComplianceBookkeeping and reporting
Separate operating results from development spending and coordinate resource-specific accounting and tax questions with industry specialists.
Exploration, development, extraction, and site obligations create different accounting questions that need more detail than a single project expense account.
Project phase budgets, mineral interest agreements, equipment schedules, production records, and site obligations give the review a practical starting point. We identify missing information before recommending changes.
Often, if the deduction offsets other income today. The deduction is recaptured when the mine starts production, so we compare the timing value with the effect on later depletion.
If it is larger than cost depletion, yes, subject to the taxable income limit from the property. Percentage depletion can continue even after the deposit's cost basis is fully recovered.
Generally when the reclamation work is performed, with special rules for certain mining reclamation reserves. We review your obligations and how they are funded.
Rules reflect federal tax law as of November 2026.