The Canada Revenue Agency has revised this memorandum which examines the election available under section 150 of the Excise Tax Act 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, license 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. 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.
This version replaces the previous one dated January 2001 and refers to the Proposed Amendments to the GST/HST Legislation and Part 1 – Selected Listed Financial Institutions Attribution Method (GST/HST) Regulations of the Draft Regulations Amending Various GST/HST Regulations released on January 28, 2011.