18 June 1997 GST/HST Interpretation HQR0000527[1] - Tax Status of the Supply of Admissions to a Convention

                                                                        11690-1(crl)
HQR0000527
ss. 123(1), 222(1), 240(1)
June 18, 1997

This is refers to your facsimile dated January 27, 1997, in which you requested information concerning the registration status of the XXXXX with respect to a convention which was held in XXXXX in 19 XXXXX

Statement of Facts

The XXXXX a resident of Canada, was not (and is not currently) registered for the Goods and Services Tax (GST).

The XXXXX holds a convention on an annual basis, hosted by a club in either XXXXX or the XXXXX When the convention is held in Canada, the majority of the delegates are resident in Canada.

The XXXXX was of the opinion that the club should be registered for the GST because it was making taxable supplies of admissions to the convention in excess of $30,000. A registration form was subsequently submitted to the Department.

When no reply was received, XXXXX contacted the Tax Services Office (TSO) and requested a ruling in regard to the convention.

 XXXXX was advised that the XXXXX should charge the GST and a provisional GST registration number was assigned to the XXXXX collected the GST on the convention and the GST was recorded in the accounts, by the auditor.

The TSO sent a letter to the XXXXX stating that it was not required to register but neither an explanation nor a ruling accompanied the letter.

 XXXXX is now requesting the GST status of the XXXXX with respect to the 19 xx convention and to future conventions, held in Canada.

Ruling Requested

The XXXXX should be registered for the GST pursuant to subsection 240(1) of the Excise Tax Act ("the Act").

Ruling Given

Based on the facts set out above, we rule that the XXXXX is required to be registered for the GST pursuant to subsection 240(1) of the Act. The amount collected by the XXXXX for the convention, as or on account of tax under Division II, is required to be remitted pursuant to subsection 222(1) of the Act.

This ruling is subject to the general limitations and qualifications outlined in the GST Memoranda Series, Section 1.4. We are bound by this ruling provided that none of the above issues are presently under audit, objection or appeal, there are no relevant changes in the future to the Excise Tax Act, and provided that you have fully described all necessary facts and transactions for which you requested a ruling.

If you have any questions or require additional information, please contact me at (613) 954-5124 or Randy Nanner at (613) 952-8810.

Cheryl R. Leyton
General Operations and Border Services Division
GST Rulings and Interpretations Directorate