The appellant issued fleet insurance policies to trucking companies who operated their vehicles in both Canada and the US. The appellant claimed input tax credits on the basis that 1/3 of its supplies of insurance were zero-rated under Sched VI, Pt. IX, s. 2(d). The 1/3 figure came from its historical analysis that 1/3 of its payouts under the policies it issued respected perils that arose in the U.S.