A law firm provides clients who are new home purchasers with an electronic version of form GST190 (respecting the new home rebate) and has them sign their rebate application electronically using a digital stylus pen, so that the purchasers “write” their signatures in the same manner they would if they were using a regular pen and paper, except that the signatures are produced and stored electronically rather than in ink on a hard copy document.
Where the builder credits the rebate to the purchaser then, once form GST190 has been so “signed” by the client, it is saved as an electronic file that the law firm subsequently transmit to the builder, who then either prints a hard copy of the signed form GST190 and mails it to the CRA, or submits the rebate application electronically through Netfile or My Business Account. In either case, the builder is required to keep a copy of the form GST190 (electronic and/or hard copy) as supporting documentation in its books and records. CRA stated:
We confirm that an electronic signature produced using […] or [a] similar device is acceptable for purposes of filing a GST/HST rebate application, provided the signature and any related electronic records exhibit the characteristics of reliability, integrity, and authenticity, as discussed in GST/HST Memorandum 15.2, Computerized Records.
