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  • Changes to the Mining Act (Québec)

    On December 10, 2013, Bill 70, An Act to amend the Mining Act, was passed by the National Assembly of Québec. Except for select provisions, the new Act took effect immediately. Amendments to the Mining Act have been in the making for some time and Bill 70 was the last iteration of what has been a lengthy process. A number of the more interventionist – some might say, extreme – measures found in earlier bills have been dropped. The new Mining Act, however, has a distinct “societal” and statist focus.For one thing, the structure of mining related rights has undergone significant changes. “Mining exploration licences” and “exploration licences for surface mineral substances”, among others, are now a part of Quebec mining history. We are left with “claims”, “mining leases”, “mining concessions” and “leases to mine surface mineral substances”. Persons wishing to prospect still must hold a prospecting licence.The new Act is, in part, oriented toward people living in areas where mining activities are carried on. A 60 day notice of staking must be given where work is to be carried on within the boundaries of a municipality and an advance notice of 30 days must be given to the municipality prior to commencement of work. Leaseholders will now be required to establish “monitoring committees” to “foster the involvement of the local community in the project as a whole”. The committees must be set up within 30 days after the lease is issued. The committees are to include a representative of business, First Nations (if applicable), the municipal sector and the public. A majority of the members must be independent from the lessee. All must be from the area in which the work is to take place. The Act is silent as to the authority of these committees. Also, any person wishing to conduct metal mining operations where production is to exceed 2,000 metric tons per day, will be required to hold a public consultation in the region where the property is located and send a report thereon to the Minister of Natural Resources and the Minister of Sustainable Development, Environment and Parks. It is not clear what the impact or implication of this measure is.When entering into a lease, the Government may, “on reasonable grounds”, require that the economic “spinoffs” - whatever these are - within Quebec “be maximized”. These terms are exquisitely vague. They will doubtlessly give rise to difficulties in attempts to procure leases from the Ministry of Natural Resources. In addition to these new hurdles, prior to the start of “mining operations” (presumably, extractive activities), and every 20 years thereafter, the lessee must send the Minister a scoping and market study “as regards processing in Québec”.Indeed, s.17 of the new Act states that “sustainable development” is a legislative objective as is development of “homegrown expertise in mineral resource exploration, development and processing”. The application for a mining lease must also be accompanied by a survey of the land parcel involved, a report on the nature, extent and probable value of the deposit, a feasibility study together with a scoping study and market study “as regards processing in Québec” (s. 101). The Act also says (s.119) that the Minister may require that an agreement be entered into with the grantee for the purpose of maximizing economic spinoffs within Quebec. Therefore, the notion of economic spinoffs is mentioned three times within the provisions dealing with the granting of mining leases. It is a clear indication as to the intentions of the current government; however, the fact that it crops up so frequently could give rise to interpretational difficulties. Further, an undue emphasis on this aspect may very well cause promoters of new projects to consider proceeding with great caution only.There are a variety of other provisions which may cause concern. For example, detailed reports on production are to be filed with the Minister annually; special declarations are required in respect of the discovery of or exploration for uranium; five percent of the land subject to a lease is to be reserved to the State “for public development purposes”; and very specific production information (including quantity and value of ore produced, royalties and contributions paid by the holder) as well as rehabilitation plans are to be disclosed publicly on an annual basis.The foregoing does not cover all the changes found in the new Act. New s. 232.2 requires that a rehabilitation plan be submitted and approved prior to commencement of operations. This may have a substantial impact on open pit mining operations. A lease will not be granted unless a rehabilitation and restoration plan is approved in accordance with the Act and a certificate issued pursuant to the Environment Quality Act. Others include the requirement that guarantees be put in place to cover the cost of rehabilitation before work commences, that such work must start within three years of cessation of operations (or sooner) and the amount of penalties which may be imposed for offences under the Act have been significantly increased.Industry participants may be well advised to carry out detailed due diligence on the attitudes of the local municipalities and First Nations in regions where they propose to stake. They may also wish to determine in advance, to the extent possible, the potential costs of rehabilitation, the possibility of carrying out processing or refining activities in Quebec and the costs thereof before investing in exploration. The new Act has increased the overall obligations of explorers and miners in Quebec and, as such, the costs associated with mineral exploration and extraction. These must be considered together with the relatively new increased royalty burden operators now face and the increases in mining taxes that will now be payable when production begins.In general, the nature of the changes made should cause explorers and operators to carefully consider new projects they may wish to initiate in Quebec.

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  • Quebec mining royalty agreements as seen through the lense of the Quebec Court of Appeal

    On August 6, 2013, the Quebec Court of Appeal rendered a very interesting decision in the case of Anglo Pacific Group plc v. Ernst & Young Inc., 9261-0690 Québec Inc.,  Northern Star Mining Corp. and Jake Resources Inc. This decision is interesting in several respects, but particularly because of the court’s analysis of the legal nature of a royalty agreement concluded in the context of Quebec mining law, and also as regards the court’s ruling on the effects of its publication in the Public Register of Real and Immovable Mining Rights,a register maintained under the Mining Act (Quebec) (“Mining Register“). Facts The debtors, Northern Star Mining Corp. and Jake Resources Inc., two gold exploration companies operating in Val d’Or, held mining claims and planned to begin extracting and exploiting ore for processing in their refinery. When the financing was extended by Anglo Pacific Group plc, the debtors signed a document entitled Senior Secured Convertible Debenture to which was attached a royalty agreement. At the time, the debtors did not yet hold a mining lease, in other words they did not yet have the right to extract the ore. Before entering into a mining lease, the debtors became insolvent and their assets had to be sold. At trial, the Superior Court found that, in the context of a vesting order under section 243 of the Bankruptcy and Insolvency Act (Canada), the purchaser acquired the property free of the royalty agreement. The Court of Appeal affirmed this judgment on this point. The court analyzed the royalty agreement under Quebec civil law, and it is this analysis in the judgment that we will be considering here. Royalty agreement: real right or personal right Firstly, the court had to decide whether the royalty agreement created real rights or personal rights, in order to determine whether these rights were extinguished by the bankruptcy and sale of the underlying assets, or if they benefited from a right to follow the property into the hands of the third-party purchaser. At the outset, the court noted that the civil law is a complete system and that we must avoid adopting principles from foreign legal systems without questioning whether they are compatible with our law, a principle previously laid down by the Supreme Court of Canada in the case of Farber v. Royal Trust Co. This warning by the court turned out to be necessary because, in its arguments, the appellant was attempting to import common-law principles applicable to mining royalties. Noting that a real right is a right in property, and not against a person, the court found that the terms of the royalty agreement under review did not have the effect of creating a real right in the minerals at the stage of the mining claim. It failed to do so because it did not confer a direct right in the minerals, as it did not give the claim holder the right to use them directly, or to enjoy or dispose of them. The payment of the royalties was subordinate to the sale by the debtors of the extracted or processed minerals. The court therefore found that the royalty agreement only created a personal right to collect the royalties. From a strictly legal standpoint, this conclusion is not surprising considering the requirements in the Civil Code of Quebec (“Civil Code“) for the creation of real rights and dismemberments of the right of ownership. The surprising element in this decision is that the court suggests, in an obiter dictum, that it would however be possible for a royalty agreement to create an innominate real right, that is to say a dismemberment of the right of ownership that is not expressly referred to in the Civil Code (such as usufruct, the right of use, servitude and emphyteusis). The court stated that it would be sufficient if the agreement granted a real right in the thing having one of the essential attributes of property – namely, the right of use (usus), the right of enjoyment (fructus), or the right to freely dispose of the property (abusus), as well as a right to follow the property in the event of a sale thereof. Interestingly, the court justified its obiter dictum in the following terms: [office translation] At a time when mining law is promising to become a driving force of the Quebec economy, the civil law must adapt without undermining the foundations of the right of property and without obscuring the conditions for the creation of a real right behind the economic and legislative reality associated with mining law. The civil law is sufficiently flexible to permit the holder of a mining claim — a potential owner of extracted minerals — to confer a real right not only in the claim, but also in the extracted minerals in respect of which the owner will obtain a right of ownership once a mining lease is granted. The court’s position is particularly surprising because the debtors only held mining claims in this case. Indeed, a claim, while characterized as a real and immovable right in the Mining Act, is, in essence, temporary and only confers on the holder thereof an exclusive exploration right limited to certain minerals. To reach this finding, the court drew a parallel between a hypothec on future rights, which is possible under Quebec law, and the potential right of the beneficiary of a mining claim to obtain a mining lease. This is only a potential right because the conditions for the issuance of the mining lease provided for in the Mining Act must first be met. It is the mining lease, once obtained, that confers on the holder the rights and obligations of an owner, including the right to extract and sell the minerals. The court then concluded that it would theoretically be possible for a royalty agreement to grant an innominate real right directly in the minerals that are eventually extracted if the holder of the claim subsequently becomes the holder of a mining lease. This would be a kind of innominate real right granted under suspensive condition that a mining lease be obtained in the future. The court is therefore opening the door to a new type of royalty agreement. Drafting such an agreement is another matter! Effects of the publication of a right in the Mining Register Secondly, the appellant maintained that the publication of the royalty agreement in the Mining Register exempted it from registration in the land register to be enforceable against third parties. On the other hand, the respondent and the impleaded party argued that the failure to register the agreement in the land register made it unenforceable against them. After considering the applicable statutes, the court made two findings: On the one hand, section 14 of the Mining Act (Quebec) provides that the transfer of a mining right or any instrument relating to such a right must be published in the Mining Register to be enforceable against the state; On the other hand, since the Mining Act (Quebec) is silent with respect to enforceability against third parties, one must defer to the general regime in the Civil Code for the publication of rights, which requires registration in the land register of all immovable real rights. Without commenting on the effect of the publication of a personal right on third parties, which would have been interesting, the court concluded that the sole effect of the publication of a right in the Mining Register is to render this right enforceable against the State, and that, to be enforceable against third parties, the royalty agreement should have been registered in the land register through registration in the Register of Real Rights of State Resource Development, since this register is an integral part of the land register. Questions may be raised regarding the impact this judgment will have on the registration in the land register of such an innominate real right at the stage of the mining claim, and on the enforceability thereof against third parties and other creditors, given that exploration rights such as mining claims are in fact exempted by the Mining Act  (Quebec) from registration in the land register, precisely in order to avoid the cluttering of the land register with registrations relating to mining exploration.

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  • Forum on Mining Royalties – Consultation document

    Here is an overview prepared by Lavery of the highlights of the consultation document (in French) released last Thursday by the Quebec government in connection with the forum on mining royalties to be held on March 15, 2013. OVERVIEW OF THE CONSULTATION DOCUMENT ENTITLED:“LE RÉGIME D’IMPÔT MINIER DU QUÉBEC” March 8, 2013 We have reviewed the consultation document entitled “Le régime d’impôt minier du Québec – mars 2013” posted on the Internet on March 8, 2013, in anticipation of the forum regarding mining royalties scheduled for March 15, 2013.This memo is not intended to be a detailed review of all items raised in the consultation document but rather a summary of the salient information contained therein. This memo reproduces the titles of the relevant sections of the consultation document.MESSAGE FROM THE MINISTERSIn 2011, half of the mining companies operating in Quebec did not pay mining royalties. The regime currently in place did not allow the community to benefit from the mining activities of public non-renewable resources despite the high prices of commodities around the world.INTRODUCTIONThe document is divided into five sections:  Overview of the mining industry in Quebec; Overview of the mining tax regimes; Analysis of the mining tax regime applicable in Quebec; Quantitative analysis of the taxes levied on the mining companies together with tax subsidies for the mining industry; and Feedback requested from the mining industry. The review undertaken by the government is governed by two principles:a) Any mining company that operates a mine in Quebec should pay a minimum mining royalty to the government in lieu of financial compensation for the exploitation of mineral resources owned by the community; andb) When the profits of the mining companies increase the Quebecers in general shall be entitled to benefit from a larger portion of these profits.The mining industry players are invited to provide comments in order to feed the reflection and discussion.1. THE MINING INDUSTRY IN QUEBEC1.1 Mineral development processSection 1.1 provides an overview of the mining industry in Quebec, mostly information you are already aware of.1.2 Mineral productionSection 1.2 of the document provides comparative data in respect of mineral production with other jurisdictions in Canada.1.3 Comparative market data of mineral production in Quebec and other jurisdictionsSection 1.3 of the document provides comparative data in respect of mineral production with foreign jurisdictions.1.4 Mining investmentsMining investments that occurred in Quebec amounted to $4.8 billion in 2012, of which 14% (i.e. $696 million) were incurred for mining exploration and development costs. These investments were made mostly in the regions of Abitibi-Témiscamingue, Côte-Nord and Nord-du-Québec. The mining investments for 2013 are forecasted at $4.1 billion.1.5 Labour matters in the mining sectorSection 1.5 provides market data on labour force in the Quebec mining industry.1.6 Economical EnvironmentThe demand for iron ore shall maintain the price of this commodity. In recent years, the prices of iron ore resulted in the development of significant mining projects in Quebec. In upcoming years, the world demand shall continue to grow but at a slower pace than the growth of the offer. The consultation document refers to an analysis of KPMG, November 2012. Based on a consensus of 13 financial institutions, on a short term basis, the price of iron ore shall be around US $130 per ton. Graphs 3 and 4 of this section set forth market data on iron ore.2. MINING TAX REGIMES2.1 Features of the types of mining tax regimesThe most common royalty regimes are the following:a) Royalties based on specific units (by volume or weight)This regime is generally suitable for bulk raw materials, materials of low value or requiring little processing, such as surface mineral substances, sand, gravel, stone, etc. It ensures stable revenues for the government, has the advantage of being transparent and requires audits of limited scope to verify the accuracy of the amounts reported. It would not be applicable in the case of metallic minerals, especially because the latter cannot be sold on the market before having undergone a treatment to extract the marketable substance.b) Ad valorem royalties based on the gross value of productionThis regime provides the government with stable revenues since the mining companies pay royalties regardless of their level of profitability. It is fairly simple to administer, but the application of a single rate limits the incentive to invest in processing activities. This is why many countries and states modulate the rate depending on the level of treatment or define the base on which royalties are levied by taking into account certain costs incurred by mining companies. However, this type of regime is less efficient in terms of economic allocation. It nevertheless remains the most common royalty regime.c) Royalties or taxes based on mining profitsThis regime is based on the computation of a mining income to which are deducted operating costs and allowances, in order to establish the value of the resource at the extraction stage. It generates an unstable income stream for the government as royalties or taxes paid by mining companies may be low or nonexistent during the first years of operation. However, this regime is very efficient in terms of economic allocation and it adjusts to prevailing market conditions. On the other hand, a low level of transparency is associated to this regime. It is typically more complex to implement and monitor, which requires an effective administration by the tax authorities.d) Royalties or taxes based on resource rentThis regime usually taxes a portion of income that exceeds a given return on investment threshold. It allows for a better distribution of income from the exploitation of the resource and has a very high level of efficiency in terms of economic allocation. Its implementation is complex and requires the development of underlying tax concepts with respect to the notion of rent.e) Hybrid regimes combining ad valorem royalties and royalties or taxes based on profits or rentHybrid regimes usually combine minimum royalties and royalties or taxes based on profits or rent. The goal is to limit the risk that the government ends up receiving no revenue if a given mining company never becomes profitable. Hybrid regimes have the advantages and disadvantages of the regimes that compose them.Table 4 at page 16 illustrates the performance of the different regimes with respect to the main governmental goals.2.2 Overview of mining tax regimes outside of QuebecTable 5 at page 17 presents an overview of the mining tax regimes of the other Canadian provinces and some foreign countries.3. MINING TAX REGIME IN QUEBECMining profits are currently taxed at a rate of 16% in Quebec. The regime applies a mine-bymine approach, meaning that a loss in respect to a given mine cannot reduce earnings from another mine.The mining profits are calculated from the gross value of the annual production of a mine, to which are subtracted some expenses and allowances (including for depreciation, postproduction development, processing, exploration and pre-production development).Table 6 at page 19 summarizes how the current mining tax regime works in Quebec.4. MINING ROYALTIES AND OTHER TAXES4.1 Evolution of mining royaltiesTable 7 at page 23 sums up the financial results of mining companies from 2000 to 2011.During this period, mining companies have reported a total gross value of production of $43.7 billion. The gross value was relatively constant for the years 2000 to 2005, but has experienced a gradual increase from 2006. From 2006 to 2011, the gross value of the annual production has more than doubled, from $3.1 billion to $7.3 billion.The industry profits have skyrocketed, particularly those of the four main producers. Between 2006 and 2011, with a gross margin of over 40%, the concept of excess profits has made its way. It is the responsibility of the government to ensure that Quebecers obtain their fair share.4.2 Imperfect regimeAlthough mining royalties have increased, half of mining companies did not pay any in 2011. These companies did not have mining profits, either because they were not profitable or because they were at the beginning of commercial operation and they claimed deductions and allowances that had the effect of reducing their mining profits to nil. Indeed, to acknowledge the investments made by the mining companies, the current mining tax regime allows them to recover a portion of their investments before subjecting them to the payment of royalties.Mining companies that paid mining tax in 2011 accounted for 81% of the gross value of annual production. These companies paid the government the equivalent of 5.9% of the gross value of production.4.3 Taxes levied on the mining companies and tax subsidies for the mining industryIn addition to the mining tax, mining companies are also subject to corporate income tax and must contribute to the Health Services Fund. However, the tax on capital was abolished in 2010.The refundable tax credit for resources is a direct assistance mechanism to support mineral exploration. The basic rate is currently 15%. As of January 1, 2014, the rate will be reduced to 10%.The flow-through share regime aims to promote the financing of mining companies. It provides for a basic deduction of 100% of the cost of flow-through shares in the calculation of the investor’s taxable income. An extra 25% deduction is granted if the expenses are incurred in Quebec by a non-operating company. An additional 25% deduction is allocated if the exploration is conducted from the surface, which gives a total possible deduction of 150% of the amount invested.4.4 Taxes levied by governmentsIn total, taxable income of mining companies is taxed at a rate of 38.6%.5. FEED-BACK REQUESTED FROM THE MINING INDUSTRY5.1 Fundamental principlesThe basic principle that will guide the government in the revision of the mining tax regime is clear: since the mineral resource belongs to the community and has a value, all companies exploiting a mine in Quebec will have to pay a royalty on the extracted resource.In parallel, the government's decision with respect to mining taxation policy will have to take into account the following objectives:5.1.1 Adequate sharing of the resource rentThe new mining regime will have to ensure a better sharing of the resource rent between Quebecers and mining companies.When the price of commodities is very high so that the profits of mining companies increase beyond a certain threshold, the government has to collect a portion of the excess profits. Mining companies argue, rightly, that the periods of high profits are offset by periods when prices are down or during which they make major investments. The new regime will therefore have to maintain a balance between the taxation of excess profits and maintaining the attractiveness of Quebec to investors.5.1.2 Optimal tax baseThe tax base of the new regime will have to provide sufficient revenues from the exploitation of the collective resource. It should encourage the influx of additional capital for exploration and development of mining projects in order to eventually create a multiplier effect. As market prices will not always be high and the existence of excess profits is not guaranteed, the chosen tax base will have to be self-sufficient for periods when there will be no excess profits.5.1.3 Efficiency of the tax system from an economical point of viewa) Stability of revenuesThe new royalty regime must generate a stable income stream for the government. However, royalties based on profits or resource rent offer less stability than the other regimes.b) FairnessThe concept of fairness will have to play at two levels in the new mining regime:a) Mining companies that generate the same amount of resource rent should be subject to the same tax rate;b) Mining companies should each pay royalties or taxes in proportion of their operating results, regardless of the level of resource rent.c) Transparency and stabilityThe new regime should allow mining companies to accurately predict the long-term tax liability associated to their activities.The new mining regime should also be transparent to Quebecers. In this regard, the new regime could be inspired from the new disclosure rules that will be introduced soon in the United States as well as the Extractive Industries Transparency Initiative to which many countries participate.d) Administrative efficiencyThe administration of the new regime should be simple for both mining companies and the government. However, this should not be at the expense of economic efficiency.On the other hand, administrative efficiency should not lead to an exploitation of the resource that is not beneficial for Quebecers as a whole, including the payment of mining royalties.e) CompetitivenessThe new system should enable companies operating in Quebec to be competitive. Many of them are also active in other parts of the world. They must remain competitive in Quebec to maintain their operations here and attract investments from their parent companies.Although Quebec has recently tightened some requirements regarding mining tax, the tax burden of mining companies is lower in Quebec than in many other countries.Many governments around the world have reformed their mining tax regimes or are considering doing the same. During the year 2010-2011 alone, at least 25 countries and states in the world have increased or announced plans to increase their mining royalties or taxes, including Australia, Peru, Tanzania, India, China, Zimbabwe, Chile, Congo, Mongolia, the Philippines, Poland and the United States.On the basis of these principles and issues, the government of Quebec considers it important to establish a constructive dialogue with the mining industry.5.2 Contemplated alternativesThe government of Quebec wants to improve the sharing of the wealth generated by the exploitation of mineral resources in the province. To do this, different options are contemplated.Choosing a hybrid regime seems more appropriate in order to combine the advantages of each regime, namely (1) guaranteed minimum revenues and (2) an appropriate sharing of the resource rent.5.2.1 Guaranteed minimum revenues: ad valorem royaltiesTo achieve the goal of guaranteed minimum revenues for the government, the ad valorem royalties constitute the best regime. It involves applying a given rate to the gross value of the annual production of mining companies. The royalties could be varied, for example, by adjusting the rate for value added products or by defining the tax base in order to avoid penalizing processing activities.The royalties could be considered as a minimum amount that must pay any company that operates a mine in Quebec and thus ensure a revenue stream to the government at any time. Once this regime is established, it should be relatively simple to administer.The ad valorem royalties could, according to the chosen approach, be deducted in the calculation of the second component of the regime.5.2.2 Appropriate sharing of the resource rentTo ensure that mining companies pay more royalties when their profitability is high, several approaches can be considered.a) Regime based on the profit marginThis regime would have the same tax base as the current one. However, the applicable rate would progressively increase once a certain level of profitability is reached. The profitability of a mining company would be determined by its profit margin.This approach would progressively increase the amount of royalties paid by mining companies. It has a high degree of economic and tax efficiency and allows an optimal sharing of the resource rent. Under this approach, a mining company would be required to pay royalties corresponding to the highest of the ad valorem royalties and the mining tax calculated on the annual profits.b) Regime based on resource rentHere, the royalties would be based on resource rent, that is to say the profits that are beyond a threshold of acceptable return on investment based on risk.This regime would have the advantage of maximizing governmental revenues when there are excess profits. It is very effective in terms of economic allocation and fairness. However, it must include clear definitions and a well-structured methodology in order to facilitate its administration.The royalties would be applied only beyond the expected return on investment. In order to guarantee a return on investment to a mining company, the profits of its activities would be tax free up to the annual deductions representing the expected return on its investment, amortized over its lifetime.If a mining company has excess profits once the ad valorem royalties are subtracted, a tax at the rate of 30% would be applied to these excess profits.The proposed formula is independent of the financing structure, allowing mining companies discretion in this regard.List of graphsGraph 1 Evolution of mining investmentGraph 2 Labour in the mining sector allocated by administrative regions in 2011Graph 3 Price of iron ore (years 2000-2013)Graph 4 World supply and demand for iron oreGraph 5 Price of gold (years 2000-2013)Graph 6 World demand for goldList of tablesTable 1 Quebec’s mineral production (2011-2012)Table 2 Value of Canadian mineral production (2012)Table 3 World production of gold and iron ore and that of Quebec and the main producing countries (2011)Table 4 Qualitative evaluation of the performance of the different types of royalties and taxes as measured against the key tax objectives of the governmentTable 5 Mining tax regimes applicable outside of QuebecTable 6 Illustration of the current mining tax systemTable 7 Data on operators (years 2000 to 2011)Table 8 Number of companies, mining tax and total gross value of mineral production (2011)Table 9 Taxes levied on mining companiesTable 10 Combined effective rate of corporate income taxes and mining tax (2013)

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  • Francization – Bill No 14 amending the Charter of the French language

    This publication was authored by Luc Thibaudeau, former partner of Lavery and now judge in the Civil Division of the Court of Québec, District of Longueuil. The title of this newsletter gives a good summary of the explanatory notes that serve as an introduction to Bill 14, entitled An Act to amend the Charter of the French language, the Charter of human rights and freedoms and other legislative provisions (the “Bill”). The legislator is concerned that English is being used systematically in certain workplaces. The Bill was tabled on December 5, 2012 and the proposed amendments are designed to reaffirm the primacy of French as the official and common language of Quebec.

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  • Bill C - 300 Accountability or Stigmatization ?

    Obviously, as regards the mining industry, Québec will not be the only jurisdiction in which action is expected after the summer break. While the parliamentary commission continues reviewing Bill 79 amending the Mining Act (Québec) , Ottawa is not outdone as the House of Commons must proceed with the third reading of Bill C-300 (the "Bill") entitled: Corporate Accountability of Mining, Oil and Gas Corporations in Developing Countries Act.

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  • Securities Brief - Forward-Looking Information

    Avoid the use of “boilerplate” disclosure Identify the nature of any material forward-looking information as well as material factors and in the disclosure documents Avoid statements pursuant to which a reporting issuer assumes no obligation to update its statements!

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