11 October 2017 Internal T.I. 2017-0719181I7 F - Agreement in writing -- summary under Paragraph (g.3)

One of the para. (g.3) conditions is that the pre-production mine development expenses were incurred under an agreement entered into before March 21, 2013. Would this requirement be satisfied where a principal-business corporation issued flow-through shares pursuant to a December 31, 2012 flow-through share agreement but incurred the 2013 expenses under the look-back rule pursuant to an agreement which it entered into with a subcontractor in 2013 but after March 21, 2013?

CRA considered it unnecessary to answer this question as, even if the relevant agreement for purposes of the March 21, 2013 cut-off was the subcontracting agreement, the expenses would qualify under para. (g.4) as having been incurred before 2015.

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