The appellant appealed GST/HST assessments for reporting periods between 2009 and 2012.
The appellant argued that its supply of independent medical assessment reports to insurance companies was an exempt supply of an 'institutional health care service' made by the operator of a 'health care facility'.
The Tax Court of Canada held that the appellant did not operate a health care facility because it did not provide medical or hospital care, and the individuals assessed were not patients of the facility.
The Court also upheld gross negligence penalties for the appellant's failure to charge and remit HST, finding the appellant was recklessly indifferent to its tax obligations.
Finally, the Court denied additional input tax credits due to a lack of prescribed supporting documentation.
The appeal was dismissed.
