President's Choice Bank v. Canada (the King), 2024 FCA 135 -- summary under Subsection 169(1)

By services, 23 August, 2024

Goyette JA contrasted s. 169(1) “which provides a formula that only awards ITCs to the extent that a good or service was used in the course of a commercial activity” (para. 40) with s. 181(5), which provided a notional ITC for a loyalty points redemption amount that was paid in the course of a financial services business provided that, at the same time, it was paid in the course of a commercial activity.

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s. 169(1) requires apportionment of an acquisition of a property or service between commercial and exempt activity
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d7 import status
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