Note that a change in wording to paragraph 8 of the Memorandum was made in February, 2012 to reflect that two corporations must be related at the time the property or service was acquired or imported.
The Canada Revenue Agency has issued this new memorandum which discusses the provisions of section 186 of the Excise Tax Act (“ETA”). If the conditions of section 186 are met, certain inputs acquired, imported or brought into a participating province by a corporation are deemed for purposes of determining input tax credits to have been acquired for use in the course of that corporation’s commercial activities.