The appellant limited partnership claimed input tax credits (ITCs) for expenses incurred by a related real estate investment trust (REIT) during public offerings and property acquisitions.
The Minister disallowed the ITCs on the basis that the expenses were incurred by the REIT, not the appellant.
The Tax Court of Canada allowed the appeal in part, finding that while the appellant could not claim ITCs for expenses related to the REIT's public offerings, it was entitled to ITCs for expenses related to property acquisitions and valuations, as the REIT acted as the appellant's agent for those purposes.
