29 September 2022 External T.I. 2022-0949081E5 - CMETC -Qualified Engineer or Geoscientist -- summary under Flow-Through Critical Mineral Mining Expenditure

Regarding the stipulation in draft para. (e) that the required certification be “completed … no more than 12 months before the time that the agreement is made,” CRA stated:

This wording suggests that the Certification is to be completed before the time the flow-through share agreement is made (but not more than 12 months before that time), although it doesn’t expressly mandate that the Certification be completed before the flow-through share agreement is made (rather than after). We have raised this issue with the Department of Finance.

While the prescribed form for the certification had not yet been released, CRA will accept a letter signed by a “qualified engineer or geoscientist” before the time the flow-through share agreement was made and that includes inter alia “a brief explanation of why it is expected that the mineral deposit(s) being explored will contain primarily (i.e., more than 50%) critical minerals” and the certifier’s professional qualifications.

CRA also indicated that the issuer’s related records should include a copy of the exploration plan.

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