File 11915-4 (DD)
Ref. 2/VI/V
Document 654
XXXXX February 23, 1995
Dear sir:
This is in response to your memo of August 4, 1994, to XXXXX concerning the application of GST to supplies made in connection with the XXXXX Event held annually by the University of XXXXX We regret the delay in replying.
Your letter indicates that XXXXX is an event offered by the University each year, in order to inform and orient prospective students and their parents with regard to the university's facilities, programs and academic system, and its way of life. The program is operated on a for-profit basis by paid employees and some volunteers (apparently less than ninety percent). No certificate or diploma of any kind is offered to the participants. XXXXX is not part of a program that consists of two or more related courses.
The information from the University which you included with your letter indicates that XXXXX is a twenty-seven hour program. On the first day students and parents are given tours of recreational facilities and opportunities to use the games room and swimming pool, and the campus pubs. Students and parents stay overnight in a university dormitory. On the second day the students and parents spend time in a classroom setting, listening to a faculty member give a mock lecture, and receiving information about counselling services and academic services from academic counsellors, learning skills counsellors and career counsellors.
You asked whether XXXXX is excluded from the exempting provisions of section 2 of Part VI by subparagraph 2(m)(ii) as a "similar event". The Gage Canadian Dictionary defines "conference" as "a meeting of interested persons to discuss a particular subject". The supply at issue would appear to fit within such a definition, or is at least similar enough to qualify as a "similar event".
The supply would therefore be excluded from the exempting provision of section 2 of Part VI of Schedule V to the Act by reasons of subparagraph 2(m)(ii). Since the supply is not exempted by section 2 of Part VI, and since no other exempting provision would appear to apply, the supply is taxable.
If you require any further information concerning this matter, please contact Mr. Don Dawson at 954-4393.
Yours truly
J.A. Venne
Director
Tax Policy - Special Sectors
GST Policy and Legislation
c.c.: |
J. Houlahan
D. Dawson |