14 September 2001 GST/HST Ruling 35456 - Relationship Clarification -

Dear XXXXX

Thank you for your letter (facsimile) of April 3, 2001 concerning the GST/HST Application Ruling (case reference number 26702) issued by the Canada Customs and Revenue Agency (CCRA) for XXXXX[.]

Statement of Facts

All facts, transactions and purpose of the transactions remain the same as stated in our letter of March 30, 2001, case number 26702, with the exception of the clarification of the relationship XXXXX[.] You are, by your letter of March 30, 2001, amending the facts to stipulate that the payroll for XXXXX activities of the XXXXX are segregated for source deductions purposes. XXXXX is not a separately incorporated entity, but simply a business operation of XXXXX.

Ruling Requested

You would like the CCRA to review the application ruling provided to you on behalf of XXXXX in our letter of March 30, 2001, case number 26702, in view of the above mentioned clarification.

Ruling Given

I wish to confirm that the ruling given to your firm on March 30, 2001, case number 26702, remains unchanged.

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 our 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) 952-4294.

Yours truly,

Francine Ménard
Border Issues Unit
General Operations and Border Issues Division
Excise and GST/HST Rulings Directorate