September 29, 1994
XXXXX
This is in reply to an electronic message from XXXXX of your staff to Mitch Bloom dated January 4, 1994, regarding the above-mentioned subject.
Facts
XXXXX
Question
You inquired as to whether the provision of the unspecified interest in the mobile home park and of the exclusive right to occupy a specific site constitute a single supply or two different supplies.
Answer
To answer your question, we analysed the provisions of the various agreements between XXXXX and the purchasers of the interest in the mobile home park. In doing so, we applied the policy in respect of single supply and multiple supplies. The provisions of the contract do not allow a clear determination as to whether the two elements described above are part of a single supply or each constitutes a separate supply, and we therefore used the three following questions to assist in making this determination.
XXXXX
Based on the above analysis, we believe that the XXXXX are making a supply by way of sale.
I hope the above will be of assistance to you. Should you wish to discuss this memo further, please do not hesitate to contact Mr. Serge Bernier at (613) 952-9580.
H.L. Jones
Director
General Tax Policy
Excise/GST
GTP: 734(REG)
c.c.: S. Farber
D. Gagnon
Imposition team
Emphasis is ours
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