23 May 2007 GST/HST Ruling 82739 - Application of GST/HST on fundraising event with a XXXXX as a prize

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.

Dear XXXXX:

Thank you for your letter XXXXX concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to "associated persons".

All legislative references are to the Excise Tax Act (ETA) and the regulations thereunder, unless otherwise specified.

Interpretation Requested

We understand that you would like to know whether the notion of being "associated" with another person is necessarily a reciprocal relationship, that is, if one person is associated with another person, does this mean that the other person is associated with the first person.

Interpretation Given

The word "associated" as it is set out in section 127 for purposes of Part IX of the Act denotes a reciprocal relation. If person B is associated to A, then A is associated to B.

The foregoing comments represent our general views with respect to the subject matter of your request. These comments are not rulings and, in accordance with the guidelines set out in GST/HST Memorandum 1.4, Excise and GST/HST Rulings and Interpretations Service, do not bind the Canada Revenue Agency with respect to a particular situation. Future changes to the ETA, regulations, or our interpretative policy could affect this interpretation.

If you require clarification with respect to any of the issues discussed in this letter, please call me directly at 613-954-4394.

Yours truly,

Doris McMullan
Corporate Reorganizations Unit
Financial Institutions and Real Property Division
Excise and GST/HST Rulings Directorate

2007/05/30 — RITS 82754 — Retroactive Adjustments to Input Tax Credit (ITC) Allocation Methods