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GST — full input tax credits allowed

My client was an institution engaged in an significant expansion. Most of its income came from donations and government funding. However, it did charge for memberships and admissions.

I helped the institution claim full input tax credits for the GST it paid on millions of dollars of construction services for its expansion. Naturally, the CRA wanted justification for the claim.

I prepared a comprehensive analysis for the CRA auditor. I detailed the various sources of the institution's income, and showed which ones of them were related to the GST claims. I demonstrated that most of the expansion related to gallery space open to the public, and that most of the use of the gallery was for public admissions, which were taxable. Based on a combination of many provisions of the GST legislation, I showed the auditor that the institution was entitled to full input tax credits.

The auditor agreed, and the institution received a very large GST net tax refund.

The institution's management were very happy.

(2005)