Allan Gelkopf, Zvi Halpern-Shavim, "Five Arbitrary Differences between Corporations and Partnerships for GST/HST Purposes", Sales and Use Tax, Federated Press, Volume XIII, No. 2, 2015, p. 674.

Summary Under
Tax Topics - Excise Tax Act - Section 186 - Subsection 186(1)

CRA apparently not following Miedzi/partnerships not covered (pp. 674-5)

Stantec. . .[and] Miedzi Copper… significantly expand the scope of ITC...

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Summary Under
Tax Topics - Excise Tax Act - Section 150 - Subsection 150(1)

Election only available for corps (p. 675)

. . . for some reason, only corporations can benefit from the section 150 election. The election does...

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Summary Under
Tax Topics - Excise Tax Act - Section 228 - Subsection 228(7)

Set-off mechanism not available for partnerships (p. 675)

Subsection 228(7) of the ETA permits a set-off of refunds or rebates under certain...

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Summary Under
Tax Topics - Excise Tax Act - Regulations - Selected Listed Financial Institutions Attribution Method (GST/HST) Regulations - Section 3 - Paragraph 3(c)new item

No SLFI permanent establishment for partnerships (p. 676)

. . . [F]or some reason, only loan corporations are deemed to have permanent...

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Summary Under
Tax Topics - Excise Tax Act - Section 272

No comparable relief for partnerships (p. 676)

…When a corporation winds up into its wholly-owned parent, the supply of property from the...

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