2 February 1998 GST/HST Interpretation HQR0000987 - GST Exemption for International or Foreign Conventions

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

Dear XXXXX

This is in reference to your fax transmissions of November 25 and November 26, 1997 with attachments, to XXXXX Tax Services Office, concerning your request for GST exemption for international or foreign conventions. More particularly, following our telephone conversations of January 15 and January 22, 1998, you request that we rule as to whether the XXXXX being sponsored by the XXXXX qualifies as a foreign convention under the Excise Tax Act (the Act).

Our understanding of the facts is as follows:

Statement of Facts

XXXXX is the sponsor of the event, having its head office in London, England, will be holding its quinquennial General Conference (the event) in Ottawa xx from XXXXX

The hosts of the conference are XXXXX and XXXXX

XXXXX is providing the secretariat for XXXXX including the mailing of the sponsor's admission fees to the conference under the sponsor's letterhead, and the collection of the admission fees from the attendees on behalf of XXXXX expects a total attendance of XXXXX persons, whereby 90% of the attendees will be nonresidents.

Ruling Requested

Whether the conference qualifies as a foreign convention, as provided for under the Act.

Ruling Given

Provided that the statement of facts is correct and complete and constitutes a complete disclosure of all facts, we rule that the XXXXX sponsored by XXXXX qualifies as a foreign convention in accordance with the definition of "foreign convention" contained in subsection 123(1) of the Act. Accordingly, the supply by XXXXX of the admissions to the convention is not subject to GST by virtue of sections 189.2 and 165 of the Act.

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.

For your information I have taken the liberty of including two GST/HST publications entitled GST Memoranda Series 27.2 and the GST/HST Information for Non-Resident Meeting Planners and Convention Organizers, respectively.

Should you have any further questions or require clarification on the above matter, please do not hesitate to contact me at 957-8220.

Daniel Chamaillard