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October 4, 2023

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

 Attn: George K. Schuler

Jenifer Gallagher

Karl Hiller

 Re: International Tower Hill Mines Ltd.

Form 10-K for the Fiscal Year ended December 31,
2022

Filed March 8, 2023

File No. 001-33638

Ladies and Gentlemen:

This letter sets forth the responses of International
Tower Hill Mines Ltd. (the “Company”) to the comments provided by the staff of the Division of Corporation Finance
(the “Staff”) of the Securities and Exchange Commission in its comment letter dated August 3, 2023 with respect
to the above-referenced Form 10-K. For your convenience, the Staff’s comments are set forth in bold below, followed by the
Company’s responses.

Form 10-K for the Fiscal Year ended December 31, 2022

General

 1. Please utilize sequential and unique numbering on the pages in any amendment that is necessary to resolve the concerns outlined
in the comments that follow.

Company Response:

We respectfully acknowledge the Staff’s comment.
The Company will utilize sequential and unique numbering on the pages of the amended Form 10-K the Company intends to file in
response to the Staff’s comments, as well as in future filings.

Financial Statements

Note 2 - Summary of Significant Accounting Policies, page FS-48

 2. We note your disclosures on pages 81 and FS-49 stating that your mineral project “is currently in the exploration and
evaluation phase” which appears to be consistent with disclosures on page 51, explaining that you expect to continue to incur
losses in the foreseeable future, expressing uncertainty as to whether you will ever begin production, and clarifying that you do not
consider the Livengood Gold Project to be commercially viable based on the prevailing commodity prices.

However, these disclosures are not consistent with numerous
disclosures elsewhere in your filing indicating the property is in the development stage and having reported proven and probable mineral
reserves for the property.

Please clarify the nature of support for any disclosures
of proven and probable reserves that you believe should be retained, including the investment and market assumptions made in formulating
a view on economic viability and compiling your preliminary feasibility study, and submit the revisions that you propose to clarify the
status of the property and to resolve the inconsistencies referenced above.

Company Response:

We respectfully acknowledge the Staff’s comment.
After a review of applicable accounting guidance and discussion with its advisors, including the Company’s independent accounting
firm, the Company has concluded that it will no longer disclose that the Livengood Gold Project (the “Project” or “Livengood
Gold Project”) is in the exploration and evaluation phase.

The Company’s disclosure on pages 81
and FS-49 of the Form 10-K was made in the context of the disclosure obligations arising under Accounting Standards Codification
(“ASC”) 915 “Development Stage Entities.” Under ASC 915, a project enters the development stage when it
is determined that commercially recoverable reserves exist (usually through completion of a bankable feasibility study) and a decision
is taken by the directors to develop the mine. The definition of development stage under ASC 915 is not consistent with the definition
of “development stage property” found in Regulation S-K Item 1300, which defines a development stage property as “a
property that has mineral reserves disclosed, pursuant to this subpart, but no material extraction.” While both definitions require
mineral reserves, a project with disclosed mineral reserves but for which a development decision has not yet been made would not be in
the development stage under ASC 915 but would constitute a development stage property under Regulation S-K Item 1300. The Company has
not yet made a development decision regarding the Livengood Gold Project and accordingly described the Project as in the exploration and
evaluation phase when discussing accounting policies but as a development stage property in all other contexts.

ASC 915 has been superseded by Accounting Standards
Update 2014-10, which removed all references to the development stage. Accordingly, the Company intends to revise its disclosure in future
filings to remove all references to the Project being “in the exploration and evaluation phase.” The Company will also revise
its disclosure in future filings to remove all references to the Company being “in the exploration stage” (see page FS-48).

Regarding support for disclosure of proven and
probable reserves, the Company respectfully refers the Staff to the Technical Report Summary (the “TRS”) appearing
as Exhibit 96.1 to the Company’s Annual Report on Form 10-K for the year ended December 31, 2022. While the Company
intends to file an amended TRS as noted below, the previously filed TRS addresses the support for proven and probable reserves in great
detail, including the investment and market assumptions made in formulating a view on economic viability, which disclosure the Company
does not anticipate changing in the amended TRS.

 3. We note your disclosures on pages 81 and FS-49 describing various circumstances under which you would test the costs capitalized
for your mineral property for impairment, which include “a current-period operating or cash flow loss combined with a history of
operating or cash flow losses,” which is consistent with FASB ASC 360-10-35-21(e).

However, we do not see any disclosures of impairment as
would be provided pursuant to FASB ASC 360-10-50-2, or of the qualitative and quantitative information that would be necessary to understand
the estimation uncertainty and the impact the critical accounting estimate has had or is reasonably likely to have on your financial condition
or results of operations, as would be required to comply with Item 303(b)(3) of Regulation S-K.

    2

We understand that the amounts you have capitalized for
the mineral property represent acquisition costs incurred predominantly in 2006, 2011 and 2012, and that the balance has remained relatively
unchanged for over ten years. We see that the balance exceeds the net present values associated with the Base Case disclosed on pages 19-7,
22-7, 22-7, and 138 of your pre-feasibility studies dated October 29, 2021, March 8, 2017, September 8, 2016, and September 4,
2013, respectively, as calculated using a discount rate of 5%. We also note disclosures on pages 51 and 67, explaining that you have
incurred losses and have had no revenue from operations since inception, which you indicate was in 1978, and that you have not completed
any material exploration on the property since 2012.

Given these various circumstances, it appears that you
would need to have conducted impairment testing in accordance with FASB ASC 360-10-35-29 through 35 on a periodic basis for an extended
period of time. Please describe to us the extent of any impairment testing that you have conducted pursuant to this guidance since 2012,
provide us with the analyses that either were conducted or that will be conducted for recoverability as of the end of your most recently
completed fiscal year, and submit any revisions that you propose to clarify your efforts and the results of your impairment testing in
this regard.

Company Response:

The Company periodically reviews and tests assets
for impairment in accordance with FASB ASC 350 “Property, Plant and Equipment” and ASC 360 “Intangibles – Goodwill
and Other” as applicable. Impairment tests are performed at least annually, and since September 2013, on a quarterly basis
but also in the event any event or circumstance indicates the carrying amount of a long-lived asset or group of assets may not be recoverable.
Attached at Annex A to this letter is the most recent annual impairment testing analysis, conducted in February 2023.
Similar analyses were conducted in connection with the quarters ended March 31, 2023 and June 30, 2023. As at June 30,
2023, the Company had approximately $55 million in long-lived assets. Excluding an immaterial amount of net property and equipment, these
long-lived assets represent mining claims and rights to mining claims located in and around the Company’s Livengood Gold Project.

Since the beginning of impairment testing in December 2012,
the Company’s market capitalization has been above the value of its net assets ($55.2 million at June 30, 2023). The assets
that are tested for recoverability are the Company’s long-lived assets related to mineral property rights and claims. At June 30,
2023, the Company’s mineral property assets totaled approximately $55 million. As these assets are all similar in nature (they represent
mining claims or rights to mining claims all within the same area), they are viewed as one asset group for impairment testing purposes.
The test for recoverability is made over the remaining useful life of the assets. The useful life of the Company’s mineral property
assets is the estimated life of the proposed mine. For each impairment test, the assets are depreciated over the mine life beginning with
production as stated in the TRS for the Livengood Gold Project. Recoverability of these assets will thus be based on the undiscounted
cash flows provided using the life of mine cash flows as depicted in the respective model used for the TRS.

The TRS details a project that would process 65,000
tons per day and produce 6.4 million ounces of gold over 21 years from a gold resource estimated at 13.6 million ounces at 0.60 g/tonne.
The TRS includes the integration of new interpretations based on an expanded geological database, improved geological modelling, new resource
estimation methodology, an optimized mine plan and production schedule, additional detailed metallurgical work at various gold grades
and grind sizes, changes in the target grind for the mill, new engineering estimates, and updated cost inputs. The TRS has estimated the
capital costs of the Project at $1.93 billion, the total cost per ton milled at $13.12, the all-in sustaining costs at $1,171 per ounce,
and the Net Present Value (5%) at $1,800/oz of $400 million.

    3

For each interim and annual impairment test, the
reporting period end price of gold is compared to the prior year-end gold price. The price of gold on June 30, 2023 was $1,912 or
$100 and 6% higher than the price of $1,812 at December 31, 2022. The Livengood Gold Project is a long-term project that will take
time to develop and eventually monetize making the use of a longer-term gold price assumption in the TRS more appropriate compared to
recent spot prices for gold.

The Company also notes that historical acquisitions
of exploration stage companies have typically occurred at values greater than the Company’s current book value of $4.06/resource
ounce ($55 million/13.6 million ounces). During September-October 2020, the Company completed an ATM sales agreement for gross proceeds
of $10.3 million and in March 2023 approved a budget of $3.3 million. These actions add further support that investors recognize
the value of the asset and are committed to advancing the Project. Based on the qualitative and quantitative factors described above,
the Company believed that no further assessment or valuation of impairment was required. The Company will continue to assess the recoverability
of its assets as circumstances or events dictate, or at least annually.

The Company believes that the long-term outlook
for the gold price and the mining industry remains positive. Therefore, through August 7, 2023 when the Form 10-Q for the quarter
ended June 30, 2023 was filed, the Company did not believe that any event or circumstance such as those listed in ASC 360-10-35-21
had occurred that would indicate that the fair value of the Livengood Gold Project would more likely than not be reduced below its carrying
value and did not believe that a triggering event had occurred that required further interim impairment testing based on the guidance
in FAS 142.

In accordance with Item 303(b)(3) of Regulation
S-K, the Company intends to expand its disclosure under “Critical Accounting Estimates — Mineral Properties and Exploration
and Evaluation Expenditures” in Item 7, Management’s Discussion and Analysis of Financial Condition and Results of Operations
of future Annual Reports on Form 10-K to note that the Company evaluates recoverability of its mineral property assets based on the
undiscounted cash flows using the life of mine cash flows as depicted in its model for the Livengood Gold Project, and the extent to which
the estimates used in the life of mine cash flows are subject to uncertainty, including as a result of the assumed gold price.

 4. We note your disclosure on page 51, referring to the document you filed as Exhibit 96.1, stating that although the Technical
Report Summary underlying your disclosures of proven and probable reserves indicates the project would generate “a minimal positive
return” using a gold price of $1,680 per ounce, the company “… would need to see higher gold prices over a sustained
period for the Project to be commercially viable.”

As the definition of preliminary feasibility study in
Item 1300 of Regulation S-K depends on the qualified person having determined that extraction of the mineral reserve is economically viable
under reasonable investment and market assumptions, it is unclear how your position with regard to the price that would yield a commercially
viable project would be consistent with reporting proven and probable reserves. It is also unclear how the Base Case that is shown on
page 19-7 of the Technical Report Summary showing an after-tax net present value of $44.6 million and an internal rate of return
of 5.3%, while assuming that the discount rate would be 5%, would need to change when using a discount rate that is reflective of and
consistent with the project uncertainties and risk.

Please consult with the qualified person involved in preparing
the Technical Report Summary regarding these observations and describe for us the assessments that were made in considering these factors
and establishing correlation between the discount rate and the uncertainties and risk of the project; or explain to us how this would
need to change to reflect reasonable investment and market assumptions.

    4

Please explain to us how you would reasonably expect to
obtain financing for the project based on the economics illustrated in the Base Case, if this is your view.

Company Response:

We respectfully acknowledge the Staff’s comment.
The risk factor disclosure on page 51 was intended to convey management’s belief that the Company will have difficulty raising
capital or arranging financing to develop the Project unless the Project satisfies the internal rates of return and risk profile demanded
by many sources of capital and financing. The Company believes that the Project is economically viable under reasonable investment and
market assumptions as set forth in the TRS, but even with that being the case, the Company may not be able to raise capital or secure
financing sufficient to develop for the Project with the current price of gold and the Project’s capital and operating costs as
set forth in the TRS. The Company recognizes the potential for confusion in its discussion of “commercial viability” and intends
to revise the risk factor in future filings as follows (additions underlined; deletions struck through):

“Our success depends on the development and operation
of the Livengood Gold Project, which is our only project.

Our only property at this time is our Livengood Gold Project,
which is in the development stage. The TRS indicates that the Project is technically feasible and marginally viable would
generate a minimal positive return at a gold price of $1,680 per ounce. The Company will n