CRA acknowledges partnership interest income anomaly in HST/GST de minimis financial institution rules

CRA has released a Memorandum (17.7) on the de minimis financial institution rules (which, in very broad brush terms, deem an entity to be a financial institution for HST/GST purposes if it had more than $10M in interest or dividend income, other than from related corporations, in the preceding year).  One of the additional observations made in this memorandum compared to the memorandum which it replaces (700-4) is that it acknowledges that interest paid by a partnership to a partner (including within a non-arm's length grouping of enterprises) is included in the $10M revenue test for these purposes.

Neal Armstrong.  Summary of Memorandum (New Series) 17.7 De Minimis Financial Institutions under ETA - s. 149(1)(b).