CRA continues to apply Miedzi narrowly

CRA indicated that, notwithstanding Miedzi, it would not accord input tax credits to a parent, whose sole activity was ownership of Opco shares, for GST/HST on document preparation services supplied to its board, and on expenses related to discussions regarding the replacement of board members (i.e., a proxy fight?). This answer was provided before the release of draft ETA s. 186(1)(c), which generally would accord ITCs respecting most overhead expenses of a parent substantially all of whose property is shares or debts of an “operating corporation.”

Neal Armstrong. Summary of 8 March 2018 CBA Commodity Tax Roundtable, Q.14 under s. 186(1).