17 April 2000 GST/HST Ruling 13393R - Tax Status of

Dear Sir:

Thank you for your letter of January 24, 2000, concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the supply of a XXXXX[.]

Statement of Facts

In reference to your letter of January 24, 2000, our understanding of the facts is as follows:

1. XXXXX[.]

2. XXXXX XXXXX[.]

3. XXXXX[.]

Ruling Requested

The supply of XXXXX is zero-rated pursuant to section 25 of Part II of Schedule VI to the Excise Tax Act (the "ETA").

Ruling Given

The supply of XXXXX is zero-rated pursuant to section 25 of Part II of Schedule VI to the ETA. Previously on December 23, 1999, in our letter (Case 13393) we provided you with a ruling on the tax status of XXXXX. This ruling was based upon a statement of facts presented in your letter and product literature of November 8, 1999. In your most recent submission, additional facts were presented for purposes of clarification. Based upon the revised statement of facts, our previous ruling of December 23, 1999 is confirmed.

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 the Canada Customs and Revenue Agency 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