27 June 2000 GST/HST Ruling 25953 - GST Rebate Eligibility

Dear XXXXX:

Thank you for your letter of January 27, 2000, concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the transaction(s) described below.

Statement of Facts

Our understanding of the facts, is as follows:

XXXXX

The XXXXX will be constructing a new building on hospital property to house the XXXXX which is currently being operated in the XXXXX operating under the authority of the XXXXX is XXXXX part of the XXXXX activities. The new building once constructed, will be used for XXXXX the XXXXX and for XXXXX providing XXXXX[.] These services are funded by the XXXXX[.]

Ruling Requested

Is the XXXXX entitled to the 83% PSB rebate for the construction of the building and the operation of the XXXXX at the XXXXX?

Ruling Given

Based on the facts set out above, we rule that the XXXXX, a XXXXX, is eligible to claim the 83% PSB rebate for GST incurred on inputs acquired to construct the building. The XXXXX is also entitled to claim the 83% PSB rebate for GST incurred on inputs acquired for the operation of the XXXXX conducted through the new facility at the XXXXX.

This ruling is subject to the general limitations and qualifications outlined in section 1.4 of Chapter 1 of the GST/HST 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 our 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) 952-9592.

Yours truly,

Michel Guay
Municipalities and Health Care Services Unit
Public Service Bodies and Governments Division
Excise and GST/HST Rulings Directorate