GST/HST Notice 308 GST/HST and Investment Limited Partnerships July 2018

Overview of formula (pp. 3-4)

Under the SLFI rules, an SLFI determines its liability in respect of the provincial part of the HST for net tax...

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Example 1 of limited partnership that uses the subscription proceeds raised under a prospectus to invest in other LPs investing in commercial real...

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Implications of ILP being an investment plan (p. 6)

It is proposed that new paragraph 149(5)(f.1) would add an ILP to the definition of investment...

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Ability of SLFI to backdate registration by more than 30 days to beginning of reporting period (p. 12)

An ILP may be able to voluntarily register...

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Filing requirement for a SLFI registrant with election for monthly or quarterly reporting period (p. 13)

If an ILP that is a registrant and an...

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Filing requirement for an ILP that is not a SLFI and not a registrant (p. 13)

If an ILP is a non-registrant and is not an SLFI, pursuant to...

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Does not permit consolidated rebate claims (p. 14)

Pursuant to subsection 54(2) of the SLFI Regulations, a manager that currently has a...

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Effect of tax adjustment transfer election (p. 15)

The effects of the tax adjustment transfer election between an investment plan and its manager...

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Late election generally not available (p. 16)

A tax adjustment transfer election should be filed before the first day on which the election is to...

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1(1)(c) and (d) of PE definition inapplicable to investment plan (p. 17)

The term permanent establishment is defined in subsection 1(1) of the...

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Deemed non-resident ILP under s. 132(6) may be deemed resident under s. 132(2) (p. 18)

[A]n ILP that would be deemed to not be resident in Canada...

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General partner may be providing its management services to LP in its separate capacity (p. 19)

[W]here a general partner of a limited partnership...

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Example 7, Scenario 1 respecting admin and management services provided to ILP ("LP Fund") by its GP ("Aco") for a monthly fee (taxable) and with...

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