The Appellant built a long-term care facility and claimed input tax credits during construction.
Upon occupancy, it reported a deemed self-supply under subsection 191(3) of the Excise Tax Act.
The Minister assessed the Appellant, applying section 191.1 to increase the GST/HST collectible to equal the input tax credits claimed, on the basis that the Appellant received government funding.
The Appellant appealed, arguing that the funding was for health care services, not accommodation.
The Tax Court dismissed the appeal, finding that the facts were identical to a previous decision (High-Crest) and that the government funding test was met because a portion of the payments was for making residential units available to seniors.
