31 March 1998 GST/HST Ruling HQR0000985 - "Like Fund-raising Events"

                                                                        GST/HST Rulings and Interpretations
                                                                                                Directorate
Place Vanier, Tower C, 10th Floor
25 McArthur Avenue
Vanier, Ontario
 XXXXX                                                                                K1A 0L5

Dear XXXXX

Thank you for your letter of September 18, 1997 concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) as it applies to section 2 of Part V.1 of Schedule V to the Excise Tax Act.

Ruling Requested

You are enquiring if the admission to a fund raising golf tournament sponsored by a registered charity would be exempt for GST purposes. More specifically, you are enquiring if the golf tournament would be considered a "like fund-raising event" as described under section 2 of Part V.1 of Schedule V to the Excise Tax Act.

Facts

The admission price for the golf tournament is $200.00. The charity issues a charitable donation receipt for $125.00 of the price of the admission.

Ruling Given

Section 2 of Part V.1 of Schedule V exempts a supply made by a charity of an admission to a fund-raising dinner, ball, concert, show or like fund-raising event, where part of the consideration for the supply may reasonably be regarded as an amount that is donated to the charity and in respect of which a receipt for income tax purposes may be issued or could be issued if the recipient of the supply were an individual.

Based on the facts set out above, we rule that a golf tournament will be considered a like fund-raising event with the result that the exemption under of section 2 of Part V.1 of the Excise Tax Act will apply to the entire admission price of $200.00.

This ruling is subject to the general limitations and qualifications outlined in section 1.4 of Chapter 1 of the GST Memoranda Series. We are bound by this ruling provided that none of the above issues is currently under audit, objection, or appeal; that there are no relevant changes in the future to the Excise Tax Act, or to departmental interpretative policy; and that you have fully described all necessary facts and transaction(s) for which you requested a ruling.

Should you have any further questions or require clarification on the above matter, please do not hesitate to contact me at (613) 952-4157.

Yours truly,

Gabrielle Nadeau
Charities, Non-Profit Organizations and Educational services Unit
Public Service Bodies and Governments Division
GST/HST Rulings and Interpretations Directorate