23 August 2002 GST/HST Ruling 37556 - Re: [The Amounts Charged by For its Supplies of Medical Reports]

Dear Sir:

Thank you for your letter of XXXXX, requesting that we reconsider the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) application ruling of XXXXX, that the amounts charged by XXXXX for its supplies of medical reports are consideration for taxable supplies. Your request is based on the Tax Court of Canada judgment in Riverfront Medical Evaluations Limited v. HMQ.

Based on the information that was provided, this letter confirms our ruling that, for purposes of the Excise Tax Act, the amounts charged by XXXXX to individuals and their primary insurers are consideration paid to XXXXX for a taxable supply. As stated in our ruling, the taxable supply consists of arranging for a medical practitioner to assess an individual and a medical report. XXXXX is required to collect the GST/HST on the consideration for this taxable supply.

Please note that the Canada Customs and Revenue Agency is appealing the Tax Court of Canada's judgment. Should you have any further questions or require clarification on the above matter, please do not hesitate to contact me at (613) 952-6761.

Yours truly,

Susan Eastman
Municipalities and Health Care Services Unit
Public Service Bodies and Governments Division