In an attempt to obtain input tax credits for GST incurred on the IPO of an income fund, the income fund and a subsidiary LP (which held the business) agreed that the taxable expenses were to be incurred for the account of the LP. After finding that such agreement was not sufficient to make the LP the "recipient" of the services, as it was not a party to the agreements with the services providers, V. Miller went on to note various deficiencies in the invoices of the suppliers, and stated (at para. 51):
[W]here an invoice represented services to both the Appellant and the Fund and I could not ascertain the portion payable by the Appellant, I did not allow the ITC involved.