Ann: Pilbara Minerals to acquire Latin Resources, page-171

You are 100% correct that an FTA is needed to qualify for IRA, and there is not currently an FTA between the USA and Brazil.

I should have been a bit more clear, but here is why I indicated the IRA connection:

1. The USA and Brazil already have an Agreement on Trade and Economic Cooperation (ATEC). This is the second-highest level of trade agreement that the US has, and is only one step below an FTA. This agreement has existed since 2011, and was updated in 2020.
2. The USA and Brazil also have a bilateral Critical Minerals Working Group (CMWG), which is specific to energy transition minerals.
3. If it weren't for the fact that Mr. Biden is so, how shall we say, "sleepy," we'd probably already have an FTA with Brazil, and it is deemed likely that either Mrs. Harris or Mr. Trump will reach an FTA with Brazil during the next presidential term, since it's low-lying political achievement fruit.
4. The main LRS mine in Brazil (people should remember that there is also a 2nd lithium mine in Argentina, a copper mine in Peru and a Kaolin mine in West Australia) is probably two years from production, maybe even a little more, so there's time for the FTA to happen.

Even if an FTA does not materialize, which could happen if either Ms. Harris wins, but the GOP holds the Senate, or if Mr. Trump wins and the DNC takes the Senate, the EU and Mercosur are currently in negotiations for the EU's version of an FTA, and the Brazilian mine could ship spodumene to the EU, instead of the USA. Brazil is the largest of the four Mercosur members, along with Argentina, Uruguay and Paraguay.

Here's a link to the various USA-Brazil economic links:

https://br.usembassy.gov/fact-sheet-trade-investment/

Best regards!