CRA does not permit cash management and return filing by a nominee to qualify it as a joint venture operator for GST/HST purposes

CRA has a long-standing published position that bare trustees or nominees cannot qualify as operators of joint ventures for purposes of the GST/HST joint venture election, even though it recognizes that it is common in the real estate industry to use nominee corporations in this way.  CRA requires the operator to have the authority to manage the day-to-day activities of the joint venture without the input or approval of the joint venture participants, and states that this requirement would not be satisfied even where the nominee "manages the collection and remittance of the GST/HST, maintains the bank accounts in the nominee’s name, and receives all payments and pays all operational expenses on behalf of the joint venture."

Neal Armstrong.  Summary of 26 November 2012 Interpretation 148931 under ETA - s. 273(1).