Précis: This is a decision on about as esoteric a point as one can get in GST/HST litigation. For the periods under appeal Farm Credit Canada claimed to be a “general corporation” for the purposes of the Selected Listed Financial Institutions Attribution Method (GST/HST) Regulations (the “Attribution Regulations”) adopted pursuant to Part IX of the Excise Tax Act (the “ETA”). CRA assessed Farm Credit on the basis that it was a “loan corporation” for the purposes of the attribution regulations. The sole question before the Tax Court was whether Farm Credit was a “loan corporation” during the periods in question under the Attribution Rules.
Farm Credit Canada v. R. - TCC: Taxpayer a “loan corporation” for GST/HST purposesREAD MORE »