- The document discusses the eligibility of a limited partner in a partnership to claim an Input Tax Credit (ITC) under the Excise Tax Act (ETA)
- The document is from the GST/HST Rulings Directorate located on the 5th floor of Tower A, Place de Ville, 320 Queen Street, Ottawa ON
- The case number associated with this inquiry is 246538
- The inquiry focuses on whether expenses paid by a limited partner to a management company qualify as unreimbursed partnership expenses under subsection 272.1(2) of the ETA
- The limited partnership agreement (LPA) was established on a specified date between a general partner (GP) and several companies as limited partners
- The LPA outlines the business of the partnership which includes acquiring real property
- The GP is authorized to enter into agreements on behalf of the partnership, though details of the fees related to these agreements were not provided
- The LPA specifies that the interest of the limited partners is represented by units, each unit representing an undivided interest in the partnership
- Limited partners have agreed to contribute capital to the partnership in specified percentages as determined by the GP
- Each limited partner is responsible for funding their share of the deposit for property acquisitions, which is credited to their capital accounts
Source: taxinterpretations.com
Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.
