The assets of a provincial limited partnership (LP1) consisted only of an interest in a real estate development partnership (LP2). Respecting a request that the registration of LP1 be changed from a date in 2016 to a date in 2013, CRA stated:
A person’s effective date of registration is the day the person first makes a taxable supply in Canada otherwise than as a small supplier. Since [LP1] undertakes activities as a member of [LP2] and makes only exempt supplies of financial services, it has not made a taxable supply. …
Paragraph (d) of the definition of “financial instrument” in subsection 123(1) includes an interest in a partnership or any right in respect of such an interest. The definition of financial service speaks of receipt as well as payment to, and so both transactions are considered exempt supplies.