CRA accepts but will not extend the Club Intrawest case

Club Intrawest found that what otherwise would be viewed as a single supply of services regarding real property (vacation homes) was to be split into two supplies: a taxable supply respecting the Canadian homes; and a non-taxable supply in relation to the non-Canadian homes. CRA has indicated that it is not prepared to extend this bifurcation approach beyond the context of determining the place of supply of a service in relation to real property.

Neal Armstrong. Summary of 8 March 2018 CBA Commodity Tax Roundtable, Q.20 under ETA s. 142(1)(d).