A resort developer supplies memberships that entitle a member to use certain real property at one or more resort locations located in Canada and outside Canada, namely, the right to use a villa or condominium at one of the resorts. The resort developer also may supply a number of points to be redeemed each year for the use of a unit.
CRA declined to comment on whether the supply of memberships or points was a supply of intangible personal property or real property in the absence of being provided with the relevant agreements other than to say that if the supply of points gave the recipient only the right to use real property, the supply would be considered as a supply of real property for GST/HST purposes.
