Can a charity with no other commercial activities register for GST/HST prior to (as contrasted to contemporaneously with) filing a s. 211 election (on the basis of the future taxable supplies by way of leasing of real property it will make once it files its s. 211 election)? CRA responded:
In order for paragraph 141.1(3)(a) to apply, the charity would have to demonstrate a clear intention to engage in a commercial activity. For example, consideration would be given to the date on which the charity intends to start making taxable supplies; the existence of proposed contracts for the supply of the property; and other evidence that would support the charity’s intention to make taxable supplies. Such a demonstration would be required regardless of whether the charity is, before the effective date of the election, not making any supplies or only making exempt supplies in respect of the real property included in the election.
