Election for exempt supplies . : Rv3-2/17-14-2011E-PDF

"Section 150 of the Excise Tax Act (the Act) provides an election that permits corporations that are members of a closely related group of which a listed financial institution is a member to elect to treat every taxable supply between them of property by way of lease, licence or similar arrangement or of a service (with certain exceptions) as an exempt supply of a financial service. A corporation making the election is deemed to be a financial institution under section 151. This memorandum examines what is meant by a closely related group and closely related corporation and outlines the effects of making the election, particularly as it relates to a registrant corporation being deemed to be a financial institution. The memorandum also refers to an election under subsection 225.2(4) that is available to selected listed financial institutions that have made an election under section 150"--p. [1].

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