Please note that the following document, although correct at the time of issue, may not represent the current position of the Agency. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence.
Excise and GST/HST Rulings Directorate
Place de Ville, Tower A, 20th floor
320 Queen Street
Ottawa ON K1A 0L5XXXXX
XXXXX
XXXXX
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Case Number: 86372
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XXXXX
XXXXX
XXXXX
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March 15, 2007
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Subject:
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Requirement to be licensed
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Dear XXXXX:
Thank you for your letter XXXXX concerning the application of the Excise Tax Act to the operations of XXXXX.
We understand that Mr. Darren Weiner of our office has already provided you with a verbal response and that you are requesting written confirmation.
Please be advised that the following is considered to be general information only and should not be construed as a definitive ruling from the Canada Revenue Agency.
The facts, as stipulated in your letter, are that XXXXX is an American based entity located in XXXXX that imports denatured fuel ethanol into Canada. The denatured fuel ethanol contains 1.96% to 4.5% unleaded gasoline or natural gasoline denaturant by volume and will not be blended to make a gasoline/ethanol fuel nor will it be sold at the retail level.
Please be advised that denatured fuel ethanol does not attract excise tax under Schedule I to the Excise Tax Act and, as such, XXXXX is under no legal obligation to apply for an excise tax licence.
Further, based on the information provided it would appear that the product meets the specifications of a denatured alcohol grade 2-F as set out in the Denatured and Specially Denatured Alcohol Regulations. Provided that the product is not sold or used as a beverage it is not subject to the excise duty provisions of the Excise Act, 2001.
We have enclosed a copy of Memorandum 2.1 of the Excise Taxes and Special Levies series that explains the procedures and requirements concerning the application for and the issuances of licences under the Excise Tax Act.
If you require clarification with respect to any of the issues discussed in this letter, please call me directly at (613) 957-7593.
Yours truly,
Robert Murray
Technical Policy Adviser
Excise Taxes and Special Levies Unit
Excise Duties and Taxes Division
Excise and GST/HST Rulings Directorate
2007/02/22 — RITS 81357 — XXXXX Insurance Company XXXXX