Selected Listed Financial Institutions Attribution Method (GST/HST) Regulations — 60.1
for a participating province (other than the selected province) in which the investment plan has a permanent establishment in the particular taxation year 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 investment plan held, on the particular attribution point, by a person that the investment plan knows, on December 31 of the particular calendar year, is resident in the participating province on the particular attribution point, B is the total value, on the particular attribution point, of the units of the investment plan other than units held, on the particular attribution point, by a person that the investment plan knows, on December 31 of the particular calendar year, is not resident in Canada on the particular attribution point, 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 investment plan held, on the particular attribution point, by a person in respect of which the investment plan does not know, on December 31 of the particular calendar year, whether or not the person is resident in Canada on the particular attribution point or, in the case of persons resident in Canada, the province in which the person is resident on the particular attribution point, 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 investment plan held, on the particular attribution point, by a person resident in Canada on the particular attribution point and in respect of which the investment plan knows, on December 31 of the particular calendar year, the province in which the person is resident on the particular attribution point, and (iii) for the purposes of subparagraphs (i) and (ii), if, for the particular attribution point, the total of all amounts — each of which is the total value of the particular units of the investment plan held on the particular attribution point by a person in respect of which the investment plan knows, on December 31 of the particular calendar year, whether or not the person is resident in Canada on the particular attribution point and knows, in the case of persons resident in Canada, the province in which the person is resident on the particular attribution point — is less than 50% of the total value of the units of the investment plan on the particular attribution point, (A) the units of the investment plan, other than the particular units, are deemed to be held on the particular attribution point by a particular person and not by any other person, (B) the particular person is deemed to be resident on the particular attribution point in Canada and in the selected province referred to in subparagraph (i) for the preceding taxation year, and (C) the investment plan is deemed to know on December 31 of the particular calendar year that the particular person is, on the particular attribution point, resident in Canada and in the selected province; and (d) if the particular attribution point is after September 30 of the calendar year in which the particular fiscal year ends, for the purposes of these Regulations and the description of C in subsection 225.2(2) of the Act and despite sections 19 and 32, the investment plan’s percentage for a participating province and for the particular taxation year is equal to the investment plan’s percentage for the participating province and for the preceding taxation year. SOR/2013-197, s. 5