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April 2024 Federal Budget Impact on Flow Through Share Structured Transactions   The Federal Budget made a significant change, substantially increasing the percentage of capital gains subject to tax. This takes effect June 25th, 2024. Any Flow-through shares bought before that date will be at the current 50% inclusion rate. To take advantage of current tax rules, the transaction must close by June 24th! In the coming days and weeks we expect tens of millions in corporate and personal flow-through share product coming down the pipeline. Consider reserving an allocation quickly as donor and investor demand is likely to be quite high between now and the June deadline.   Here are the basics: The Federal Budget surprised everyone in the flow-through mining and critical-mineral industry by increasing the capital gain inclusion rates from 50% to 66% as of June 25th. Flow-through shares have a zero adjusted cost base. Therefore, 100% of the proceeds of sale is a capital gain. By participating before June 25th, you save the extra 16% inclusion - a material benefit. There is no change to the inclusion rate for individuals if the total capital gain is below the $250k threshold. Over ~$350K of flows puts you in the higher capital gain inclusion rate of 66%. We can calculate a blended rate benefit for large buyers.    After June 25th, corporate flow purchases will probably no longer be beneficial. But we do have corporate product coming soon and will close well before the June 25th deadline.   The key is to get in touch and get on the client waiting list.   * New 2024 Alternate Minimum Tax (AMT) calculations will replace the old AMT immediately. For personal flow buyers, this will mean the maximum you can purchase is approximately a third less than the maximum in past years. We can estimate what your current maximum would be. AMT does not apply to corporations, hence there is an opportunity to decrease corporate tax to zero.    Together, with our industry partners at the Mining Association of Canada (MAC), the Prospectors & Developers Association of Canada (PDAC), and many others, our team has started engaging with government to demonstrate how this increase to the capital gains inclusion rate will have a devastating impact on our country’s Critical Mineral Strategy and charitable flow donations. There is no guarantee that we can persuade Finance to make changes. But we are trying.   Our flow-through structure with immediate liquidity accounts for approximately 85% of all critical mineral junior mining exploration in Canada. The Canadian government has publicly stated many times that there is no path to zero carbon without critical minerals. Finance may not be aware of the damage to charity critical mineral structured flows their capital gain increase will have, and we will be lobbying officials to reconsider this as it applies to mining and exploration in Canada.

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