The Appellant, a Crown corporation operating a ferry service, appealed GST/HST reassessments for reporting periods between 2006 and 2012.
The issue was the Appellant's entitlement to input tax credits for property and services used in its commercial activities, which involved both taxable and exempt supplies.
The Tax Court found that the Appellant's space-based allocation methodology was fair and reasonable, allowing the appeals and referring the reassessments back to the Minister for reconsideration based on the Appellant's calculated percentages.