19 March 2007 GST/HST Interpretation 81842 - Definition of "Practitioner" in Part II of Schedule V to the Excise Tax Act

Please note that the following document, although correct at the time of issue, may not represent the current position of the Agency. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence.

Dear XXXXX:

Thank you for your letter XXXXX requesting a ruling on the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to XXXXX. Supplied with your letter was a copy of the XXXXX.

During our telephone conversations, additional information, as well as a third party authorization form was requested from you. I understand that you have attempted to obtain the information and the third party authorization from XXXXX and their lawyers. Without this information I am unable to provide a ruling with respect to the questions that were asked in your letter. Therefore, the case has been closed.

However, if your client still wishes the CRA to issue a ruling, we will be pleased to reopen the case once the following information and third party authorization form have been received. At that time we would need a complete copy of the XXXXX, a complete and final copy of XXXXX, and any other specific documentation XXXXX describing and explaining the activities of XXXXX. We would also require the third party authorization form signed by your client. For your convenience a copy of GST/HST Memorandum 1.4, Goods and Services Tax Rulings is enclosed. This memoranda contains the information that is required with respect to a third party authorization.

As well, I had requested information on the following questions:

•   Who do the assets used by the XXXXX belong to XXXXX?

•   Who approves the books and records of XXXXX at year-end?

•   Is the office of XXXXX on a reserve?

•   What other activities, if any, is XXXXX involved in as it appears from the information provided that they may do more than XXXXX?

Should you have any further questions or require clarification on the above matter, please do not hesitate to contact me at (613) 954-7954.

Yours truly,

Karen Bennett
Aboriginal Affairs Unit
Public Service Bodies and Governments Division
Excise and GST/HST Rulings Directorate

2007/03/21 — RITS 81870 — Acquisition of Farmland Held in Joint Tenancy