A for-profit corporation (the "Corporation") provides a service for fees to the families of non-resident minor children in consideration for arranging for them to study at a Canadian school district, stay at a Canadian home and participate in eight recreational activities to be arranged by the Corporation. The students are recruited through non-resident commission agents, the Corporation contracts directly with and pays the Canadian host families and pays tuition to the school district for schooling the children pursuant to a memorandum of understanding with the school district. CRA finds that there is a single supply, and as "academic instruction is the dominant element of the supply...all the elemens included in the package have the same tax status as the dominant element," and "the Corporation is making a single supply of a service of instructing an individual in a course." Such supply is exempt under Sched. V, Part III, s. 9(a).
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