In connection with rulings on the consequences of the seizure by creditors and resale by them of resort points, the Directorate noted that the portion of sold resort points that was considered to be supplied in Canada was determined by prorating the consideration payable by a recipient of resort points based on the extent to which the resort points represented a right to use real property situated in Canada. The parties made this determination by calculating, at the time of sale, the ratio of Canadian points (namely, resort points issued by the Club in respect of real property in Canada) available for sale, to the total number of World points available for sale.
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