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1. What
An investor in an investment limited partnership
(ILP) that is subject to the request for
information rules for the 2025 calendar year is generally required
to provide, within the prescribed delay, certain information as of
September 30, 2025 (Information), to the ILP. The
Information varies depending on which category the investor fits
in.
An ILP is a limited partnership the primary purpose of which is to
invest funds in property consisting primarily of financial
instruments and, if:
- it is represented or promoted as a hedge fund, investment limited partnership, mutual fund, private equity fund, venture capital fund or other similar collective investment vehicle; or
- 50% or more of the total value of all the interests in the ILP is held by listed financial institutions.
An ILP is subject to the request for Information rules for the 2025 calendar year if, at any time, during the year:
- it is qualified, under the laws of Canada or a province, to sell or distribute its interests in several provinces, at least one of which is an HST Province and, for QST purposes only, in Québec and at least in one other province; or
- its investors reside in multiple provinces, at least one of which is an HST Province and, for QST purposes only, in Québec and at least in one other province.
2. Who
In general, any investor in an ILP who receives a written request from an ILP subject to the request for Information rules for the 2025 calendar year, must respond by providing the Information.
In general, an investor in an ILP subject to the request for Information rules for the 2025 calendar year:
- whose total value of interests held, or category of interests held in the ILP, is less than CA$10,000,000 as of September 30, 2025, and
- who qualifies as an investment plan (other than a distributed investment plan)*,
is required to provide the Information, even if they have not received a written request from the ILP.
*The terms "investment plan" and "distributed investment plan" are defined in the legislation.
3. When
An investor who, following a written request from the ILP, is required to provide the Information must provide it on or before the particular day that is the later of November 15, 2025, and the day that is 45 days from when it received the written request.
An investor who is required to provide the Information, without a written request from the ILP, must do so on or before November 15, 2025.
4. Default
An investor who is required to provide the Information in response to a written request from the ILP, and who fails to provide it or misstates such Information is liable to a penalty. For each such failure, the penalty is equal to the lesser of CA$10,000 and 0.01% of the total value, on September 30, 2025, of the interests the investor holds in the ILP with respect to which the Information was required.
An investor who is required to provide the Information without a written request from the ILP, and who fails to provide it is liable to a penalty. For each such failure, the penalty is equal to the lesser of CA$10,000 and 0.01% of the total value, on September 30, 2025, of the interests the investor holds in the ILP with respect to which the Information was required.
5. Where
Section 52 of the Selected Listed Financial Institutions attribution Method (GST/HST) Regulations (SOR/2001-171).
Sections 433.25 to 433.32 of the Act Respecting the Québec Sales Tax Act (C.Q.L.R., c. T-0.1)
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