Please note that the following document, although correct at the time of issue, may not represent the current position of the Canada Revenue Agency. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence du revenu du Canada.
GST/HST Rulings Directorate
5th floor, Tower A, Place de Ville
320 Queen Street
Ottawa ON K1A 0L5
[Addressee]
Case Number : 246538
[Dear Client]
Subject: GST/HST INTERPRETATION
Determining if a limited partner of a partnership can claim an ITC
[…][Thank you for] your request of [mm/dd/yyyy] […][about] whether a particular amount paid by a limited partner of a limited partnership to a management company is an unreimbursed partnership expense described in subsection 272.1(2) of the Excise Tax Act (ETA) giving rise to the limited partner being eligible to claim an input tax credit (ITC) under section 169 in respect of the GST/HST relating to this expense.
All legislative references are to the ETA unless otherwise indicated.
[Statement of Facts]
Limited Partnership Agreement
1. A limited partnership agreement (LPA) effective as of [mm/dd/yyyy] was entered into between […][general partner] (the GP) and the following [#] companies who are limited partners of the partnership:
* […][limited partner 1] (LP1)
[…]
2. Section [#] of the LPA states that the name of the limited partnership is […] (LP).
3. Section [#] of the LPA states that the business of the LP is to acquire real property described in […] the LPA and […]: namely:
* The lands municipally known as […], having an area of approximately [...] shown as […] on the draft reference plan dated [mm/dd/yyy] prepared by […].
4. Section [#] of the LPA provides that the GP is authorized by the limited partners to enter into a [agreement 2] and a [agreement 3] for and on behalf of the LP, […]. We were not provided with a copy of […] indicating the fees payable by the LP in respect of the [agreement 2] or the [agreement 3].
5. […].
6. Section [#] of the LPA provides that the interest of the limited partners is divided into and represented by units and each unit represents an undivided interest in the LP and all of which together represent the interest of the limited partners in the LP. […].
7. Section [#] of the LPA provides that each limited partner agrees to contribute capital to the LP in such amounts that may be determined by the GP. If the GP determines that additional capital is required by the LP, the GP may request in writing […] that each Limited Partner contribute capital to the LP in the percentages set out in the LPA. […]. The limited partners have agreed to contribute and maintain capital in the LP in accordance with the following percentages:
[…]
8. Section [#] of the LPA also provides that each limited partner has funded, or will upon request of the GP, fund its proportionate share of the deposit relating to the acquisition of the properties and such amounts are to be credited to the capital accounts of the limited partners and treated as their capital contributions.
9. Section [#] of the LPA provides that the GP maintains a separate account for each partner.
10. Section [#] of the LPA provides that the LP will reimburse the GP for all direct costs actually incurred by the GP in the performance of its duties under the LPA.
11. Section [#] of the LPA provides that the GP has unlimited liability for the debts, liabilities and obligations of the LP and full and exclusive right, power and authority to manage, conduct, control, administer and operate the business and affairs and to make all decisions regarding the undertaking and business of the LP.
12. Section [#] of the LPA sets out the specific powers and duties of the GP.
13. Section [#] of the LPA provides that no limited partner in its capacity as a limited partner shall:
* Take part in the control or management of the business of the LP or exercise any power in connection therewith;
* Execute any document or take any action which binds or purports to bind any other partner or the LP;
* Hold itself out as having the power or authority to bind any other partner or the LP; or
* Have any authority or power to act for or undertake any obligation or responsibility on behalf of any other partner or the LP.
14. Section [#] of the LPA provides that the liability of each limited partner for the liabilities and obligations of the LP shall be limited to its capital contribution plus its share of any undistributed income of the LP, and each limited partner shall have no further liability for any other debts, liabilities or obligations of the LP and shall not be liable for any claims or assessments or be required to make further contributions to the LP except as specifically provided for in the LPA.
[agreement 2]
15. [agreement 2] effective as of [mm/dd/yyyy] was entered into between the GP acting as agent of the LP and [limited partnership Y] and [corporation 1]. [limited partnership Y] and [corporation 1] are collectively referred to as the Manager in the [agreement 2].
16. Pursuant to the recitals of the [agreement 2], the LP has engaged the Manager to carry out […]with respect to the Project in consideration of certain fees, all set out in the [agreement 2].
17. Section [#] of the [agreement 2] provides that the LP has appointed and retained the Manager as an independent contractor to manage and supervise the development of the Project.
18. Section [#] of the [agreement 2] provides that the Manager will employ personnel to develop the Project including the services of an experienced senior supervisory executive satisfactory to the LP. All matters pertaining to the employment, supervision, compensation, promotion and discharge of employees comprising such staff will be the responsibility of the Manager, which is in all respect the employer of such employees.
19. Section [#] of the [agreement 2] provides that for managing and supervising the Project, the Manager shall be paid a […] (Management Fee) in the amount of […]% of the Project Revenue for each phase of the Project. The LP will also pay to the Manager the GST/HST payable in respect of the Management Fee. The payment on account of the Management Fee shall be payable directly to [limited partnership Y] and [corporation 1] in equal shares.
[agreement 4]
20. An [agreement 4] dated [mm/dd/yyyy] was entered into between [corporation 1] (the Employer) and an unnamed employee. The [agreement 4] does not set out any particular services to be performed by the employee.
21. The [agreement 4] is an amending agreement that relates to an [agreement 5] dated [mm/dd/yyyy]. The purpose of the [agreement 4] is […](Project Bonus) […]. […].
22. Section [#] of the [agreement 4] sets out […]Project Bonus […].
23. Section [#] of the [agreement 4] sets out the rules around the payment of the Project Bonus. It essentially provides that it is [corporation 1] or an affiliate, at the sole discretion of [corporation 1], that will pay the employee the Project Bonus. Pursuant to […], [corporation 1] and LP1 are affiliated under subparagraph 251.1(1)(c)(i) of the Income Tax Act as they are both wholly owned by [corporation 2]. As such at the discretion of [corporation 1], LP1 may be the one to pay the employee the Project Bonus.
24. Section [#] of the [agreement 4] states that the Project Bonus is […] not part of the employee’s regular compensation from [corporation 1] or any of its affiliates.
[agreement 6]
25. A [agreement 6] was entered into between LP1 and [corporation 2]. The [agreement 6] is undated.
26. In the Recitals to the [agreement 6], it is stated that LP1 and [corporation 2] were parties to a [agreement 2] dated [mm/dd/yyyy] in respect of […], where LP1 was a limited partner of [limited partnership Z] and [corporation 2] was one of the development managers.
27. In the Recitals to the [agreement 6], it is noted that:
* LP1 had agreed to a [agreement 6] in [mm/yyyy] to reimburse [corporation 2] for any bonus amounts paid to the employees of [corporation 2] as result of the profitability of the Project, at the time of completion of the Project.
* The [agreement 7] was not included in the [agreement 2] because it was a separate arrangement between LP1 and [corporation 2] which did not involve the other parties to the [agreement 2] (that being the LP and [limited partnership Y] who are the other parties to the [agreement 2] that was provided to us as support for LP’s ITC claim).
* The [agreement 7] was not memorialized in writing because LP1 and [corporation 2] are affiliated corporations (as noted above, LP1 is wholly owned by [corporation 2]).
* Upon completion of the Project, LP1 paid $[…] plus GST/HST in the amount of $[…] to reimburse [corporation 2] for employee bonuses.
[documentation]
LP1 has no other activities other than holding interest in the LP. LP1 was not involved in commercial activities, never charged, collected or remitted GST/HST.
28. During the […], LP1 reported non-taxable investment income and gain on sale of investments. LP1 also reported [management fees] in the amount of $[…] on its […] ending [mm/dd/yyyy].
29. LP1 was incorporated on [mm/dd/yyyy] and it registered for GST/HST purposes effective [mm/dd/yyyy].
30. [corporation 1] issued an invoice dated [mm/dd/yyyy] to LP1 in the amount of $[…] plus GST/HST in the amount of $[…] for corporate management services from inception to [yyyy]. LP1 paid the invoice and was not reimbursed by the LP and this amount contributed to LP1’s loss from operations from the LP for income tax purposes.
31. The amount paid by LP1 to [corporation 1] was not included in the income or loss of the LP.
32. LP1 claimed ITCs of $[…] on its [mm/yyyy] GST/HST return, which included $[…] from the supplier of accounting services.
33. […].
34. […].
35. LP1 stated that, although the invoice from [corporation 1] has the description of corporate management services from inception to [yyyy], the invoice relates to Bonus Payments which did not become payable until after [mm/dd/yyyy] in relation to the sale of the […].
36. LP1 and [corporation 1] had not filed an election under section 156.
INTERPRETATION REQUESTED
You would like to know whether LP1’s payment to [corporation 1] in the amount of $[…] plus GST/HST in the amount of $[…], to reimburse [corporation 1], for a Project Bonus payment made by [corporation 1] to its employee, which we understand was made in respect of the [agreement 4] made between [corporation 1] and it employee, is an unreimbursed partnership expense described in subsection 272.1(2) and LP1 is eligible to claim input tax credits (ITCs) under section 169 in respect of the GST/HST paid in relation to this reimbursement.
INTERPRETATION GIVEN
Based on the facts set out above, we are unsure as to which entity LP1 made the payment in the amount of $[…]. Per the invoice that was provided, LP1 made the payment to [corporation 1], while according to the [agreement 5], LP1 made the payment to [corporation 2]. Regardless as to who LP1 made the payment, LP1’s payment of $[…] plus GST/HST in the amount of $[…] is not an unreimbursed partnership expense described in subsection 272.1(2) and LP1 is not eligible to claim ITCs under section 169 in respect of the GST/HST paid in relation to this expense. The facts indicate that this payment was not in respect of the LP’s business.
GST/HST treatment of partnership expenses
Under common law a partnership is not a legal entity but instead a relationship between persons such that if one contracts with a partnership one contracts with the persons who are at the time of the contract its partners. However, for purposes of the GST/HST, a partnership is included in the definition of person and as such is treated as if it were a separate legal entity from its members. While the treatment of a partnership as a separate person from its members for GST/HST purposes represents a deviation from partnership law, the CRA relies on the relevant partnership law applicable in the province or territory in which the partnership operates to determine the existence of a partnership and the rights and obligations of the members of the partnership.
Note that the terms partner or member are referenced in various sections of the ETA. These two terms are used interchangeably in this memorandum, whether a partner of a partnership or a member of a partnership.
Subsection 272.1(1) sets out the general rule under which things done by a person as a member of a partnership are deemed to be done by the partnership in the course of the partnership’s activities and not by the person. This includes supplies of property and services made to, and acquisitions of property and services made from, third parties when the member is acting in the course of the partnership’s business.
Therefore, a partner may not claim an ITC in respect of the expenses of the partnership on its individual GST/HST return, even if the expenses were incurred by the partner in furtherance of the partnership’s business. It is the partnership who is the person who carries on or engages in the activities of the partnership for purposes of the GST/HST. This means that the partnership is the reporting entity for the business carried on in partnership and is the person who registers and files GST/HST returns to account for any GST/HST owing or to claim any ITCs or net tax refund to which the partnership may be entitled in respect of its business.
It is our view that the general rule under subsection 272.1(1) would typically apply to general partners since provincial partnership law provides that only general partners act as an agent of the partnership for the purpose of the business of the partnership. Further, limited partnership agreements typically provide that only the general partner has authority to enter into contracts on behalf of the limited partnership and conduct business on behalf of the limited partnership.
Subsection 272.1(2) provides an exception to the general rule in subsection 272.1(1) where a partner acquires, imports or brings into a participating province property or a service for consumption, use or supply in the course of the partnership’s activities, but not on the account of the partnership. In other words, where the costs of the acquisition, importation or bringing in of the property or service is directly charged to or paid from an account of the partner rather than an account of the partnership.
In that circumstance, paragraph 272.1(2)(a) provides that, except as otherwise provided in subsection 175(1) in the case of a reimbursement, the partner’s act of acquiring, importing or bringing into a participating province property or a service is deemed not to be an act of the partnership. The exception to the general rule applies when expenses have been incurred by the partner in carrying on the business of the partnership where no reimbursement is provided and it recognizes that the business to which these expenses pertain is not the partner’s business but the business of the partnership.
Paragraph 272.1(2)(b) provides that where a partner that is not an individual acquires, imports or brings into a participating province property or a service for consumption, use or supply in the course of activities of the partnership, but not on the account of the partnership, for purposes of determining an ITC of the member, subsection 272.1(1) does not apply to deem the partner not to have acquired, imported or brought in the property or service and the partner is deemed to be engaged in those activities of the partnership.
The effect of paragraph 272.1(2)(b) is that the partner may, in its own right, be eligible to claim an ITC under section 169 in respect of the acquisition, importation or bringing in of the property or service, but only in the case where the partner is not an individual and is not reimbursed for the expense by the partnership. The partner will have to satisfy the conditions for claiming the ITC, such as obtaining the necessary supporting documentation and having its own GST/HST registration.
For subsection 272.1(2) to apply in respect of property or a service that is acquired, imported or brought into a participating province by a partner, it is not enough that the consumption, use or supply of the property or service simply relates to, or benefits, the activities of the partnership. Rather, it must be the case that the property or service is intended to be consumed, used or supplied in the course of the activities of the partnership. Since the rule in subsection 272.1(2) is an exception to the general rule in subsection 272.1(1), this will generally be the case where the acquisition, importation or bringing in of such property or service by the partner is a usual act undertaken in the ordinary course of the partnership business such that subsection 272.1(1) would otherwise apply to that partner’s action.
As noted above, the application of subsection 272.1(1) would generally be limited to the actions of a general partner. Therefore, the exception rule in subsection 272.1(2) would not apply to the actions of a limited partner of a partnership other than in an extraordinary circumstance that would require factual and documentary support that a limited partner’s action would have otherwise been subject to the rule in subsection 272.1(1). Accordingly, there would have to be evidence of an express agency in writing that is referenced in the limited partnership agreement authorizing a limited partner to enter into a specific agreement on behalf of the limited partnership or other documentary evidence that an expense incurred by a limited partner was in fact an expense of the partnership for which the limited partner was not entitled to a reimbursement from partnership funds.
To be an expense of the partnership, it cannot be the case that a particular partner decided itself to pay for something. It is also noted that partnership law provides that partners own assets and owe liabilities of partnerships jointly with other partners. Therefore, all of the partners would have to agree collectively if particular partnership expenses are to be borne by individual partners. We would therefore expect that a partnership agreement contain a clause stating that it is agreed that a partner is expected to incur and pay certain types of expenses. This clause is important because the members of a partnership and the partnership are separate persons for GST/HST purposes and one person cannot claim the ITCs of another person. Without such a clause, it would be difficult to determine whether the expense was an ordinary and necessary business expense of the partnership for consumption, use or supply in the course of the activities of the partnership or whether the partner decided itself to pay the expense without any agreement by the other partners.
In summary, the following questions can assist in substantiating a claim that an expense incurred by a partner would otherwise be an expense of the partnership:
* Is the partner’s action consistent with the relevant partnership law?
* Is the partner’s action consistent with the terms of the partnership agreement, for example, was the partner acting within the scope of the particular partner’s authority as provided under the partnership agreement?
* Is the expense in question identified in some manner as an expense the partners had agreed they would incur, for example, by routine practice as necessary in the business of the partnership?
* Can it be substantiated that the acquisition of the property or service was for consumption, use or supply in the course of the business of the partnership?
Comments on agreements provided
The agreements provided do not substantiate that the payment made by LP1 to [corporation 1] to reimburse [corporation 1] in respect of a Project Bonus payment [corporation 1] made to its employee was consideration in respect of a supply of a service acquired by LP1 for consumption, use or supply in the course of the activities of the LP. This reimbursement was done under an unwritten [agreement 7]Side Agreement made between LP1 and [corporation 2] that purposely did not involve the LP.
In [mm/yyyy], the GP, acting as agent of the LP, entered into a [agreement 2] with [corporation 1] and [limited partnership Y] pursuant to which [corporation 1] would provide development management services in respect of the LP’s activities (the Project). Under the [agreement 2], the LP agreed to pay a specific Management Fee for each phase of the Project directly to [corporation 1] and [limited partnership Y] in equal shares. The LP did not agree to make any Project Bonus payment to [corporation 1] or [limited partnership Y] as there were no provisions under the [agreement 2] that relate to any Project Bonus payment.
In [mm/yyyy], [corporation 1], which is not a member of the LP, entered into an [agreement 4] with its employee to amend the employment agreement that it had previously entered into with the employee by adding a Project Bonus payment. Pursuant to section [#] of the [agreement 4], the payment of the Project Bonus will be made by [corporation 1], or an affiliate at [corporation 1]’s sole discretion, to the employee. As LP1 is an affiliate of [corporation 1], [corporation 1] may at its sole discretion allow LP1 to pay the Project Bonus to the employee. With the existence of the undocumented side agreement between [corporation 1] and LP1, [corporation 1] used that discretion to have LP1 pay the Project Bonus to the employee.
The payment of the Project Bonus was described, under section [#] of the [agreement 4], […]from [corporation 1] or any of its affiliates. At a subsequent point in time, the [agreement 6] was entered into between LP1 and [corporation 2] pursuant to which LP1 agreed to reimburse [corporation 2] in respect of the Project Bonus payment.
We do not see a connection between the Project Bonus payment made by [corporation 1] to its employee in the [agreement 2]. The [agreement 4] providing for the Project Bonus payment by [corporation 1] was entered into after the [agreement 2] had been signed and doesn’t amend the [agreement 2] nor does it involve the LP. Rather, we see the Project Bonus payment as agreement made solely between [corporation 1] and its employee. We also note that:
* The [agreement 4] providing for the Project Bonus payment was a separate and distinct agreement from the [agreement 2].
* The payment of the Project Bonus to the employee by LP1 was solely done at the discretion of [corporation 1] pursuant to section [#] of the [agreement 4].
* There is no evidence that the LP gave any consideration to the Project Bonus payment set out under the [agreement 4].
* Pursuant to section [#] of the LPA, LP1 had no authority to execute any document or take any action, obligation or responsibility which binds or purports to bind any other partner or the LP.
* The LP’s only payment obligation to [corporation 1] was to pay a Management Fee as set out in the [agreement 2].
We also note that [corporation 1] had no right to receive any monies from the LP representing the Project Bonus payment. If [corporation 1] had such a right, there should be evidence of this right.
If the Project Bonus payment made by [corporation 1] to its employee has no relevance to the activities of the LP, it follows that LP1’s reimbursement paid to [corporation 1] in respect of this payment has no relevance to the activities of the LP.
In any event, we will consider the terms of the [agreement 6]. We note that:
* The [agreement 6] was entered into long after the [agreement 2] had been signed and does not amend the [agreement 2] nor does it involve the LP.
* By executing the [agreement 6], LP1 became obliged to pay a substantial fee ostensibly for services the LP had already received from [corporation 1] for which it had paid a Management Fee.
* The [agreement 6] providing for the Project Bonus was a separate and distinct agreement from the [agreement 2].
Although the Recitals to the [agreement 6] refer to LP1 and [corporation 2] being parties to a [agreement 2], we note that neither LP1 or [corporation 2] are parties to the [agreement 2] provided to us as support for LP1’s ITC claim. Further, we do not construe the Recitals to the [agreement 6] as giving an implied agency to LP1 with respect to the reimbursement of the Project Bonus payment to [corporation 1]. We also do not construe the fact that LP1, as a limited partner of the LP, was a party to the [agreement 2]. Rather, only the GP, as agent of the LP entered into the [agreement 2] on behalf of the LP.
In this case we note the distinction between the parties to the [agreement 2] that was provided in support of LP1’s ITC claim, which does not include [corporation 2]. In any event, we will assume for purposes of this query that LP1 agreed to reimburse [corporation 1] for a Project Bonus payment, including GST/HST, made to an employee of [corporation 1].
We note that [corporation 2] is not a member of (the LP) and we were not provided with a partnership agreement for [limited partnership Z], which was referred to in the [agreement 6], and have no knowledge of [corporation 3]’s involvement in the activities in question that would possibly relate to LP1’s ITC claim. We also note that it was [corporation 1] that invoiced LP1 and not [corporation 3].
If LP1 had signed the [agreement 6] as agent of the LP, the obligation to make the payment would have been binding on the LP. However, we have not been provided with any evidence of an express agency in writing authorizing LP1 to enter into the [agreement 6] on behalf of the LP to reimburse [corporation 1]. There is no evidence that the [agreement 6] was approved by the GP of the LP, that the LP was bound by the terms of the [agreement 6] and that there was assent by the LP to the terms of the [agreement 6]. Thus the [agreement 6] or any other contract could not have been made under the powers of agency between LP1 and the LP.
LP1 has not substantiated a business purpose for the Project Bonus payment relating to the activities of the LP. For whatever reason LP1 was willing to reimburse [corporation 1] in respect of the Project Bonus payment, it cannot have been for the purpose of the LP’s business. The nature of the LP’s business and management is determined by reference to the LPA, which provides, in part, the following:
* Only the GP is liable for the LP’s obligations with full and exclusive right, power and authority to manage, conduct, control, administer and operate the business and affairs and to make all decisions regarding the undertaking and business of the LP.
* The limited partners are only responsible for funding their proportionate share of the deposit relating to the acquisition of the properties and such amounts are to be credited to the capital accounts of the limited partners and treated as their capital contributions.
* No limited partner in its capacity as a limited partner may, among other things, execute any document or take any action which binds or purports to bind any other partner or the LP and have any authority or power to act for or undertake any obligation or responsibility of any other partner or the LP.
* The liability of each limited partner with respect to the LP’s business is limited to its capital contribution.
For example, section [#] of the LPA provides that the GP is authorized by the limited partners to enter into the [agreement 2] for and on behalf of the LP, in the form, including the fees payable by the LP in respect of the [agreement 2], approved by […]. We were not provided with a copy of [a document] to indicate that a reimbursement of the Project Bonus payment made by [corporation 1] to its employee was accepted by all of the members of the LP collectively as an allowable expense of the partnership.
The LP did not include the payment in its calculation of the profits of the business of LP and there is no evidence that the payment was accepted by all of the members of the LP collectively as an allowable expense of the partnership. LP1’s reimbursement to [corporation 1] for the Project Bonus payment was not authorized by the LP and was not accounted for in the LP’s financial records. The bonus payment was not allocated to the other limited partners commensurate with their capital investments in the LP. LP1 was not expected to self-fund any business expenses of the LP and there is no evidence that the LP had a routine practice requiring the limited partners to pay any partnership expenses outside the terms of the LPA.
With respect to the set of questions noted above that we identified that can assist in substantiating a claim that an expense incurred by a partner would otherwise be an expense of the partnership, we note that:
* LP1’s reimbursement to [corporation 1] is not consistent with the relevant partnership law, which provides that only general partners act as agents of the partnership.
* LP1’s reimbursement to [corporation 1] is not consistent with the terms of the LPA, which provides that only the GP is liable for the LP’s obligations and no limited partner has authority to take any action which binds or purports to bind any other partner or the LP and have any authority or power to act for or undertake any obligation or responsibility of any other partner. Therefore, LP1 was not acting within its authority as provided under the LPA.
* The reimbursement of the Project Bonus was not an expense the partners of the LP had agreed to incur and as an extraordinary expense, it was not an expense paid by the limited partners by routine practice as necessary in the business of the partnership.
* It cannot be substantiated that the reimbursement of the Project Bonus payment was for consumption, use or supply in the course of the business of the LP.
In summary, the reimbursement of the Project Bonus payment made to [corporation 1] in respect of which LP1 claims falls within the exception rules in subsection 272.1(2) to justify the ITC claim is an expense that LP1 chose to incur, rather than an expense called for under the LPA. In other words, it would appear that LP1 decided itself to reimburse [corporation 1] for the Project Bonus payment.
In any event, whatever the purpose for LP1 agreeing to reimburse [corporation 1] in respect of the Project Bonus payment, that purpose was other than for being consumed, used or supplied in the course of the LP’s business. The fact that LP1 reimbursed [corporation 1] does not make the reimbursement itself an expense of the LP nor is it evidence that the expense was incurred for consumption, use or supply in the course of the business of the LP.
DISCLAIMER
In accordance with the qualifications and guidelines set out in GST/HST Memorandum 1-4, Excise and GST/HST Rulings and Interpretations Service, the interpretation(s) given in this letter, including any additional information, is not a ruling and does not bind the Canada Revenue Agency (CRA) with respect to a particular situation. Future changes to the ETA, regulations, or the CRA’s interpretative policy could affect the interpretation(s) or the additional information provided herein.
CONTACT
If you require clarification with respect to any of the issues discussed in this letter, please call me directly at 613-292-0461.
Should you have additional questions on the interpretation and application of the GST/HST, please contact a GST/HST Rulings officer at 1-800-959-8287 or by fax to 1-418-566-0319.
Mathieu Purney
Senior Rulings Officer
Financial Services Unit
Financial Institutions and Real Property Division
GST/HST Rulings Directorate
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