PWC, "GST/HST and QST alert: Investment plans are required to obtain investor percentages – action required by October 15, 2019", PwC Tax Insights, September 03, 2019, Issue 2019-31

Summary Under
Tax Topics - Excise Tax Act - Regulations - Selected Listed Financial Institutions Attribution Method (GST/HST) Regulations - Section 52 - Subsection 52(10)
overview/qualified investors should be contacted

Qualifying investors

A qualifying investor is generally an investor that is an investment plan (but not a DIP) that holds less than $10,000,000 in...

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Summary Under
Tax Topics - Excise Tax Act - Regulations - Selected Listed Financial Institutions Attribution Method (GST/HST) Regulations - Section 52 - Subsection 52(1) - Qualifying Investor
overview

Qualifying investors

A qualifying investor is generally an investor that is an investment plan (but not a DIP) that holds less than $10,000,000 in...

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Summary Under
Tax Topics - Excise Tax Act - Regulations - Selected Listed Financial Institutions Attribution Method (GST/HST) Regulations - Section 52 - Subsection 52(4)
October 15 deadline under e.g. s. 30(1)(b)A4 -C(ii)

Timing

DIPs must know where their unitholders resided or their “investor percentages” by December 31 of the particular year; however, as there...

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Summary Under
Tax Topics - Excise Tax Act - Regulations - Selected Listed Financial Institutions Attribution Method (GST/HST) Regulations - Section 48 - Subsection 48(1) - Paragraph 48(1)A(b) - Element 48(1)A(b)A6 - Subparagraph 48(1)A(b)A6(ii)
desirability of making reconciliation election

Current year election

Generally, DIPs determine their provincial attribution percentage based on the default attribution point (i.e. September 30,...

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