CRA finds that a fee received by a broker for finding a purchaser for a financial business is not HST/GST exempt

CRA found that a fee earned by a non-resident broker for assistance in finding a purchaser to close on an exempt sale of a financial operation was predominantly paid for taxable advisory services – as well as being tainted by the new s. (r.4) rule as being for "customer assistance" provided before the sale.

In addition to the absurdity of the implication that such fees only avoid (r.4) if the dealer does not provide any customer assistance before generating its fee on closing, this appears to be contrary to Global Cash Access - which suggests that because the services of the dealer are of no use to the client unless the sale closes, arranging for that financial service is what the client is paying for rather than the pre-closing "advice" and "assistance."

Neal Armstrong.  Summary of 4 February 2014 Interpretation 106288 under ETA – s. 123(1) – financial service.