There are various arbitrary GST distinctions between corporations and partnerships

There are a number of somewhat arbitrary GST distinctions between corporations and partnerships. Partnerships:

• cannot access the s. 186 election to permit a holding partnership to claim input tax credits;
• cannot use the s. 150 election to exempt intra-group supplies even if the partnership is a listed financial institution or is closely related to a listed financial institution;
• do not qualify for the off-set mechanism permitting a large GST remittance obligation of one member of a closely related group to be reduced by the refund position of another group member;
• do not benefit from any analogue to the s. 272 rule deeming the conveyance on a corporate wind-up to not be a supply.

Neal Armstrong. Summaries of Allan Gelkopf, Zvi Halpern-Shavim, "Five Arbitrary Differences between Corporations and Partnerships for GST/HST Purposes", Sales and Use Tax (Federated Press), Vol. XIII, No. 2, 2015, p. 674 under ETA s. 186(1), s. 150(1), s. 228(7), s. 272 and Selected Listed Financial Institution Attribution Method (GST/HST) Regulations, s. 3(c).