CRA confirms that a group Finco is a listed financial institution for GST/HST purposes

CRA has revised and expanded its Memorandum on what is a listed financial institution for GST/HST purposes.  New points include:

• The "insurer" branch of LFI also includes non-provincially licensed insurers such as accident and sickness insurers.
• The "money-lender" branch includes in-house Fincos (so that, for example, a group with a Finco could make s. 150 elections to eliminate HST/GST on intercompany lease or services charges).
• A person who is deemed by s. 149(3) to be an FI by virtue of an acquisition from an FI of what will be continued as its principal business is not thereby also deemed to be an LFI (unless it satisfies the specific criteria).

Neal Armstrong.  Summaries of Memorandum 17-6 "Definition of ‘Listed Financial Institution’" July 2014 under ETA s. 149(1)(a) and s. 149(3).