Selected Listed Financial Institutions Attribution Method (GST/HST) Regulations — 31
ating province (in this paragraph referred to as the “selected province”) having the highest tax rate on the first day of the particular fiscal year is the percentage determined by the formula (A/B) + (C × A/D) + [(1 – C) – (D/B)] where A is the total of all amounts, each of which is the total value of the units of the financial institution held, on the particular day, by a person that the financial institution knows is resident in the selected province on that day, B is the total value, on the particular day, of the units of the financial institution other than units held on that day by a person that the financial institution knows is not resident in Canada on that day, C is the lesser of 0.1 and the amount determined by the formula C 1 /C 2 where C 1 is the total of all amounts, each of which is the total value of the units of the financial institution held, on the particular day, by a person in respect of which the financial institution does not know whether or not the person is resident in Canada on that day or, in the case of persons resident in Canada, the province in which the person is resident on that day, and C 2 is the amount determined for B, and D is the total of all amounts, each of which is the total value of the units of the financial institution held, on the particular day, by a person resident in Canada on that day and in respect of which the financial institution knows the province in which the person is resident on that day, (ii) the financial institution’s percentage as of a particular day in the particular fiscal year for a participating province (other than the selected province) in which the financial institution has a permanent establishment in the taxation year in which the particular fiscal year ends is the percentage determined by the formula (A/B) + (C × A/D) where A is the total of all amounts, each of which is the total value of the units of the financial institution held, on the particular day, by a person that the financial institution knows is resident in the participating province on that day, B is the total value, on the particular day, of the units of the financial institution other than units held on that day by a person that the financial institution knows is not resident in Canada on that day, C is the lesser of 0.1 and the amount determined by the formula C 1 /C 2 where C 1 is the total of all amounts, each of which is the total value of the units of the financial institution held, on the particular day, by a person in respect of which the financial institution does not know whether or not the person is resident in Canada on that day or, in the case of persons resident in Canada, the province in which the person is resident on that day, and C 2 is the amount determined for B, and D is the total of all amounts, each of which is the total value of the units of the financial institution held, on the particular day, by a person resident in Canada on that day and in respect of which the financial institution knows the province in which the person is resident on that day, and (iii) for the purposes of subparagraphs (i) and (ii), if, for any particular day in the particular fiscal year, the total of all amounts — each of which is the total value of the particular units of the financial institution held on that day by a person in respect of which the financial institution knows whether or not the person is resident in Canada on that day and knows, in the case of persons resident in Canada, the province in which the person is resident on that day — is less than 50% of the total value of the units of the financial institution on that day, (A) the units of the financial institution, other than the particular units, are deemed to be held on that day by a particular person, (B) the particular person is deemed to be resident on that day in Canada and in the selected province referred to in subparagraph (i) for that day, and (C) the financial institution is deemed to know that the particular person is