Written Submission for the Department of Finance Canada Pre-Budget Consultations in Advance of the 2025 Budget

4 Recommendations:   

 1. Modify the Alternative Minimum Tax (“AMT”) schedule to reduce the negative economic impact on the mineral exploration industry by: 

   a) Eliminating the phantom capital gain in line 1 of the AMT Schedule; and 

   b) Reducing the add back of Canadian Exploration Expenses (“CEE”) as funded through the Flow-Through Share (“FTS”) structure to 30%. 

 2. Renew the Mineral Exploration Tax Credit (“METC”) for 5 years beyond March 2025, and extend the Critical Mineral Exploration Tax Credit (“CMETC”) by 3 years, from 2027, thereby aligning the two incentives to expire March 2030. 

 3. Make all 34 minerals on Canada’s Critical Minerals List eligible for the CMETC and update section 248(a), the definition of “mineral resource”, in the Income Tax Act (Canada) (“ITA”) to read: “a base or precious metal or a critical mineral”. 

 4. Provide authority to the Minister of Natural Resources to allow an extension of expenditure timelines associated with FTS in the event of unforeseen situations (e.g. wildfires, floods, etc.) that create significant liabilities for resource companies and their FTS investors.