Department of Finance Canada Pre-Budget Consultations in Advance of the Fall 2025 Budget

Seven Recommendations:  

1. Alternative Minimum Tax (AMT) – For AMT purposes only, eliminate (1) the 100% of the capital gain add-back; AND (2) the Canadian Exploration Expense deduction add-back resulting in an accretive $350M annually in exploration financing. 
2. CRA Requests for Information it Already Possesses – Stop the CRA’s practice of requesting redundant information as a condition of issuing tax refunds, resulting in over $200M of lost exploration investment annually, while costing the federal treasury tens of millions of dollars in interest and human resources. 
3. Provide Clarity on the Definition of Canadian Exploration Expense (CEE) – Publish a statement confirming CRA agrees with the Supreme Court of BC’s interpretation of the FTS regime i.e. that expenditures up to the decision to develop a mine fall within the CEE definition adding an accretive $500M annually in exploration and development financing. 
4. Expand the Canadian Development Expense (CDE) Definition – Once a decision is made to develop a mine, all expenditures, including capital equipment, should qualify as CDE. Additionally, FTS funded development expenditures should be deductible by the FTS subscriber over two years at 50% annually, replacing the current 37.5% declining balance. 
5. Expand Flow-Through & Critical Mineral Exploration Tax Credit (CMETC) Eligibility – Make all 34 minerals on Canada’s Critical Minerals List CMETC-eligible by amending ITA section 248(a) to define ‘mineral resource’ as ‘a base or precious metal, or a critical mineral as defined by Natural Resources Canada”. 
6. Mineral Exploration Tax Credit (METC) and CMETC – Make METC and CMETC permanent. 
7. Set Price Floors to Provide Certainty – Implement a government-backed price support mechanism, like a contract for difference (CFD), to guarantee minimum revenue for critical mineral producers, mitigating market manipulation risk.