The Saskatchewan advantage
Opportunities for bolstering Canada’s leadership in critical minerals, including copper, abound in resource-rich Saskatchewan. BJP7images via getty images
What if you could donate to a charity of your choice and – at the same time – support the local resource industry?
Accelerating philanthropic impact and mineral exploration with flow-through share financing
Across Canada, there is a heightened focus on advancing resource sovereignty, with a spotlight on the critical minerals needed for energy security.
In addition to the federal government’s critical mineral strategy, provinces are looking to amplify the advantages of abundant mineral deposits and a sector that has a reputation for responsible and sustainable practices to enhance economic and community well-being.
Saskatchewan is no exception – and Ron Bernbaum, founder and CEO of financing platform PearTree Canada, believes his company’s unique value proposition can help make a difference by unlocking the powerful benefits of mineral exploration while, at the same time, supporting philanthropic endeavours.
“This creates the opportunity for people to donate money to a local school or hospital – and do that in a fashion that creates jobs in the Canadian resource sector. That’s a double social benefit.”
PearTree provides an investment platform that funds over $500-million annually in resource exploration capital through the flow-through share tax regime while simultaneously funding charities. Mr. Bernbaum goes on to explain, “a flow-through share is nothing more than a newly issued common share, where the resource issuer use of funds is limited to exploration as defined in the Income Tax Act. The tax deductions and credits that may otherwise be available to the issuer incurring the exploration activities are flowed through to the subscriber funding the activity – largely labour.”
In a simple three-step process, Canadian taxpayers subscribe for flow-through shares accessing both federal and provincial tax incentives, in this case Saskatchewan tax incentives. The shares are then immediately donated to the charity or charities the subscribers support. The charity then immediately sells the shares to a pre-arranged investor located anywhere in the world.
This convergence results in an amplification of benefits for different stakeholders. Accessing two sets of tax benefits for one cheque reduces the after-tax cost of donation to less than 3 per cent of the donation amount in Saskatchewan. The reduced cost results in greater donations. For the resource issuers, the shares are issued at a premium, reflecting the value of equity and of the tax benefits – reducing dilution. By separating the tax benefits from the equity, that equity can be sold at a discount to market to global investors.
“This creates the opportunity for people to donate money to a local school or hospital – and do that in a fashion that creates jobs in the Canadian resource sector,” he says. “That’s a double social benefit.”
Mr. Bernbaum says that PearTree consists of “two businesses running side by side: one faces the philanthropic community and the other plays an integral role in the Canadian mining sector. We source $500-million in flow-through shares for donation purposes, and this money finances jobs in the resource industry. That’s almost half of all resource financing in the country in any one year.”
The genesis of PearTree
How did PearTree arrive at such a powerful impact? It started in 2006 with a change in the Income Tax Act, where the federal government removed capital gains tax on donations of publicly listed securities.
This inspired the question whether the capital gains tax on publicly listed flow-through shares, designed to fund resource exploration in Canada, could be eliminated as well if the funds were donated to a charity. The idea piqued the interest of Mr. Bernbaum, a tax lawyer by profession, who had, together with his wife, been active in philanthropic causes.
“I went to the tax authority,” he recalls. “I asked that if I bought a flow-through share otherwise trading at $1 on the TSXV at a premium, paying $1.25 a share, and donated it to a charity the same day – followed immediately by the charity selling the shares for $0.85, could the donor access both the $1.25 flow-through exploration deductions and the $0.85 donation receipt? No market risk.”
After a year of submissions, a positive response was issued by the Canada Revenue Agency, through an Advanced Income Tax Ruling, confirming the tax consequences of the A to B to C structure. It set PearTree on a trajectory of 17 years of impact that includes completing more than 700 flow-through financings and funding well over $4-billion in exploration capital.
“Back then, I didn’t anticipate that we were building a business that now employs over 40 people across the country,” Mr. Bernbaum says. “Fast forward to 2025, and we close 60 deals a year.”
A boon for charities and donors
Early milestones include PearTree’s first capital campaign for a Montreal McGill hospital 17 years ago. Two new mammography machines were needed to significantly reduce wait times and improve patient outcomes by reducing radiation exposure and false positives.
An anticipated six-month campaign, seeking to raise $2.5-million, came to fruition in weeks. Later campaigns were similarly successful. For example, when a sum of $18-million was needed for a new campus for a Christian school system in B.C., the fundraising team “hit a wall at $14-million,” Mr. Bernbaum recalls. “PearTree was introduced to the charity, and through a lunch-and-learn series, the goal was met – essentially the same donor group was able to give more at a reduced cost of giving.”
What’s more, current technology makes this a seamless process. Funds come in electronically when deals close and are – if everything is aligned – disbursed immediately. “The charities receive the funds the same day,” he says. “We close deals typically on a Thursday morning, 60 to 62 times a year, every year.”
The value to charities is significant, and donors welcome the opportunity to “divert tax money to charitable causes. It inspires them to give more – and faster,” he adds.
De-risking mineral exploration
“While we’re important to the philanthropic community, we’re even more important to the mining sector,” proposes Mr. Bernbaum. Although there is wide recognition of the benefits of the mineral industry, an inherent uncertainty in discovering and developing economically viable resource deposits – paired with market volatility and potential operational challenges – mean that resource exploration carries considerable financial risk.
“Junior exploration is venture capital at its riskiest,” he says. “We buy high, providing a premium to market when the shares are first issued, thus reducing issuer dilution. We donate and sell low, reducing the cost of capital for global investors in Canadian resources, acquiring the shares from the charities at 15 to 20 per cent discounts to market.”
In addition, global investors value that the funds must be spent on direct exploration. In essence, the Canadian Income Tax Act sets out governance.
“When global investors invest in Canada, that translates into a Canadian advantage,” adds Mr. Bernbaum. “We’ve done a very good job of marketing this approach internationally, largely in Europe, Asia and Australia.”
Proven model for better outcomes
Recognizing the economic impact of the flow-through regime, the federal government has already expressed support in expanding it, says Mr. Bernbaum, who sees this as a way to bolster Canada’s resource independence.
“We need exploration, and we need critical minerals to drive our economy,” he says. “Take copper and lithium, for example. Without copper, there’s no electricity. Lithium also remains an important requirement for battery technology essential for renewable energy sources for the next 15 to 20 years.”
PearTree was part of a group that lobbied the government for the expansion of the flow-through regime to include the extraction of lithium from brine, a space in which Saskatchewan could be a leader, says Mr. Bernbaum. “Once the technology is figured out, over the next three to four years, capped oil wells could be re-opened to extract lithium from the brine.”
Opportunities abound in resource-rich Saskatchewan, “and we hear a lot of exciting things about this province,” he adds. And since “flow-through regime tax incentives outperform any other way of raising money quickly in sectors that are important to Canada,” putting them to work in Saskatchewan will pay large dividends in terms in generating economic activity and delivering community impact.
To further strengthen its presence in Saskatchewan, PearTree has expanded its team of dealing representatives with the addition of Elaine Kosmas, based in Saskatoon. Ms. Kosmas’s local presence reinforces PearTree’s commitment to engaging directly with Saskatchewan’s communities, charities and resource sector stakeholders.
“A $1 tax deduction in Saskatoon results in $1 of taxable economic activity in the Athabasca Basin, for example,” says Mr. Bernbaum, who looks forward to engaging charities, donors and mineral exploration companies in Saskatchewan.
To view this report on The Globe's website, visit globeandmail.com
To view the full report as it appeared in The Globe's print edition The Saskatchewan advantage