You are an Examiner for the Refund Integrity Program in the GST/HST Audit Division of the Canada Revenue Agency (CRA). Using sophisticated analytical tools, you are able to identify GST/HST returns that have a high risk of containing errors or omissions. You are currently working on a pre-assessment review for a GST/HST return filed by Kellogg Adelaide Ltd. (KAL) for its April 1-June 30, 2021 reporting period. The return was filed claiming a refund of $62,973. Using records accessible by the CRA, you are able to determine that KAL was incorporated on February 4, 2021 and has not yet filed a corporate tax return. The company also registered a GST/HST account on April 25, 2021 with an effective registration date of April 1. Filing frequency is quarterly and the period under review is KAL's first GST/HST filing. You have sent a pre-assessment review letter to the business address on file requesting a description of the commercial activity, a detailed general ledger of sales and input tax credits (ITCs), and copies of the five largest sales and purchasing invoices. KAL's accounting controller has submitted the following information in response to your letter: KAL is engaged in the development and construction of a new residential condominium building at 9000 Adelaide Street in Toronto, Ontario. The parcel of land was purchased on April 25, 2021 for $16,000,000. Revenue will come from the sales of the individual condominium units upon the building's completion in 5 years. The only revenue in the period was a management fee of $25,000 received from Kellogg Yonge Street Inc. (KYSI), a corporation wholly owned by the same individual who owns KAL. No HST was charged on this fee by KAL and no ITC was claimed by KYSI since the parties have made a closely related group election. The controller was able to provide a copy of the completed election form. The following breakdown was provided for the $62,973 of ITCs reported: