6 December 2002 Memorandum RITS 35845

The provision of temporary accommodation at a boarding home for individuals requiring medical treatment off-site represented the single supply of a right to stay at the home which, to the extent that the individuals stayed for more that one month at the home, was exempted under s. 6(a) of Part I of Schedule V.

A home that received funding from Public Works and Government Services Canada ("PWGSC") for providing temporary accommodation to individuals receiving medical treatment at another location was found to be making a supply to PWGSC given that PWGSC used a standing offer (indicating that the payments were for purchase purposes) and given the view of the Directorate that PWGSC was contracting-out one of its own programs rather than financially supporting the activities of the home.

GST Memorandum (New Series) 3.1 "Liability for Tax", para. 4-8

A home at which a class of individuals was entitled to stay at temporarily while awaiting medical treatment off-site was not available to members of the public at large and, therefore, did not constitute a hotel, motel, inn, boarding house, lodging house or similar premises for purposes of the definition of residential complex.

The provision of temporary accommodation at a boarding home for individuals requiring medical treatment off-site represented the single supply of a right to stay at the home which, to the extent that the individual stayed for more that one month at the home, was exempted under s. 6(a) of Part I of Schedule V.