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Written Submission to the Department of Finance Canada for the Pre-Budget Consultations in Advance of the Upcoming Federal Budget

1. Either roll back the Alternative Minimum Tax (AMT) rates to the 2023 levels for all investments including capital gains, or adopt the August 12, 2024 legislative proposals by Finance Canada allowing for a full deduction of Canadian Exploration Expenses (CEE) funded under the Flow-Through Share (FTS) tax regime without the add-back to AMT.

2. Adopt the test for CEE as set out in the Seabridge Gold decision in the Income Tax Act (ITA) of Canada.

3. Stop CRA Requests for Information it Already Possesses.

4. Expand & Simplify the Canadian Development Expenses (CDE) Definition.

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. Make the Mineral Exploration Tax Credit (METC) and CMETC permanent.

7. Make Qualifying Environmental Trusts (QET) eligible for funding through the FTS tax regime.

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