Yes. Let me clarify that. The basic rule is that in order for the claimant to get the full tax credit, as you indicated, 10% of the hours that are completed by Red Seal trades have to be done by apprentices.
However, to your point, the rules include circumstances.... One of the things we heard from businesses or proponents when we consulted on the draft legislation was that in some circumstances it can be hard to find apprentices, especially in the current environment. There are labour shortages in some areas, particularly in remote areas. The notion was that if you make reasonable efforts to try to find apprentices to fill in those hours, you can be deemed to have filled those hours. The Americans have something very similar. The idea was to have something similar here.
To complete this, I can be pretty precise about what it means for employers to be deemed to have taken such reasonable efforts in respect of the apprenticeship hours. There are really three things that they need to do.
First, they have to post a job advertisement, including a commitment to facilitate the participation of apprentices in a Red Seal trade on multiple websites for 30 days that are open to both existing employees and new hires.
Second, they need to communicate with at least one secondary school or educational institution that can be reasonably expected to facilitate the hiring of an apprentice position as described in the job ad.
Third, they're expected to communicate with the union that can be expected to facilitate the hiring of the apprenticeship positions described in the job ad and receive written confirmation from the union if they're unable to fulfill the request for the apprenticeship. If an employer does not hear back from the union within five business days from the request, the written confirmation is not required.
To close, these hiring efforts would need to be completed every four months. Now, if they do that and they still don't fill the 10%, they're deemed to have satisfied the requirement.