CRA’s decision to not appeal University of Calgary does not mean that it would not challenge similar ITC methodologies

University of Calgary found that UC's method of calculating input tax credits was fair and reasonable even though equal weight was given to: (often exempt educational) building space (with all of its infrastructure); and a (commercial) parking lot space. CRA commented:

Although the CRA did not appeal…, in subsequent cases with similar types of entities we will be taking a close look… keeping in mind that, an ITC allocation method must reasonably reflect the actual use of the inputs and the manner in which the person conducts its business generally. For example, a university whose predominant purpose is education and research would generally not acquire its main campus over 40% for the purpose of making taxable supplies for consideration.

Neal Armstrong. Summary of May 2016 Alberta CPA Roundtable, GST Q.15 under ETA s. 141.01(2).