Two-tier joint ventures are not accepted for GST/HST purposes

Where all the members of a real estate joint venture (JV-1) enter into a 50-50 joint venture (JV-2) with a seventh person respecting a further property, JV-1 and JV-2 will be treated as separate joint ventures, so that a decision to have a GST joint venture election in place for JV-2 and not JV-1 will be respected.  Furthermore, all participants in JV-2 will need to make the JV-2 joint venture election.

Neal Armstrong.  Summary of 12 July 2013 Interpretation 152393 under ETA - s. 273.