CRA refers to an “ongoing review” of what is a participant in a JV for GST purposes
Medallion expanded the concept of a “participant” beyond CRA’s administrative definition of that term, by characterizing a person who contributed services to the joint venture to be a “participant” in the joint venture. P-106 only includes a person who has contributed property to the joint venture, or a person with no financial interest, who is responsible for the managerial or operational control of the joint venture.
When asked whether it has completed its review of Medallion, CRA stated:
Whether the Court’s decision in Medallion …would apply to another situation would require examination of all the relevant facts and documents. As part of our ongoing review of the policy, we will continue to consider similar cases as they arise.