SEC Comment Letter 0000000000-25-003298 to PROVINCE OF BRITISH COLUMBIA (CIK 0000836136)
PROVINCE OF BRITISH COLUMBIA (CIK 0000836136)
Date: March 27, 2025 · CIK: 0000836136 · Accession: 0000000000-25-003298
AI Filing Summary & Sentiment
File numbers found in text: 333-285485
Show Raw Text
March 27, 2025
Douglas Scott
Deputy Minister of Finance
Province of British Columbia
Consul General of Canada
466 Lexington Avenue, 20th Floor
New York, New York 10017
Re:Province of British Columbia
Registration Statement on Form S-B
Filed March 3, 2025
File No. 333-285485
Dear Douglas Scott:
We have reviewed your registration statement and have the following comment(s).
Please respond to this letter by amending your registration statement and providing
the requested information. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments.
Registration Statement on Form S-B, Filed March 3, 2025
Amendment No. 4 to Annual Report on Form 18-K, Filed March 7, 2025
Budget and Fiscal Plan 2025/26 - 2027/28
Tax Measures
Carbon Tax Act, page 66
1.We note your disclosure that should the federal government remove the requirement
for carbon pricing across Canada, British Columbia would follow suit. Please update
your disclosure to confirm, if true, that British Columbia intends to end the province's
consumer carbon tax now that Prime Minister Mark Carney has moved to eliminate
the tax. In addition, if the end of the consumer carbon tax has an impact on British
Columbia's revenues and projected revenues, please update your disclosure as
necessary.
March 27, 2025
Page 2
General
2.On March 13, 2025, the British Columbia Legislative Assembly advanced legislation
titled the "Economic Stabilization (Tariff Response) Act." In response, federal
legislators in the United States have suggested reviving COVID-19 legislation,
namely the "Cruising for Alaska's Workforce Act," that would allow cruise ships to
return to the mainland United States without stopping in a foreign country. Please
provide updated disclosure on the potential impacts of this legislation and, if
necessary, the potential targeted responses against British Columbia - similarly to how
you provided "Recent Updates" disclosure in your 18-K amendment on December 31,
2024.
3.On March 23, 2025, Prime Minister Mark Carney called a snap election for April 28,
2025. Please provide updated disclosure to reflect any impacts, if material, to British
Colombia due to the running and potential consequences of these federal elections.
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence
of action by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
Please contact Nicholas Nalbantian at 202-551-7470 or Michael Coco at 202-551-
3253 with any questions.
Sincerely,
Division of Corporation Finance
Office of International Corporate
Finance
cc:Jason Lehner