The registrant, who had a quarterly GST reporting period, had acquired a property for personal use, but converted it to commercial use (for short-term rentals) in the second quarter of 2005. The Minister denied his claim at the end of 2009 for an input tax credit on the basis that the four-year limitations period in s. 225(4)(b) had commenced on 1 July 2005.
VA Miller J dismissed the registrant's appeal. She stated (at para. 15):