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XXXXX Ltd. is a major provider of employee services to employers (payroll services, human resources management, benefits administration, etc.). ... These include: •   the place where agents or employees of the non-resident are located; •   the place of delivery; •   the place of payment; •   the place where purchases are made or assets are acquired; •   the place from which transactions are solicited; •   the location of assets or an inventory of goods; •   the place where the business contracts are made; •   the location of a bank account; •   the place where the non-resident's name and business are listed in a directory; •   the location of a branch or office; •   the place where the service is performed; and •   the place of manufacture or production. ... Yours truly, Michael Place Border Issues Unit General Operations and Border Issues Division Excise and GST/HST Rulings Directorate 2006/01/24 — RITS 63749 — GST Exemption Certificate ...

You have provided and example of one such Partnership Agreement [...] ... In exchange for performing the above services, […] of Agreement #1 generally entitles the Manager to earn from the partnership an annual investment management fee […]. The Manager is also entitled to an annual property oversight fee […], pursuant to […] Agreement #1. ...

The lawyer specializes in Human Resources and Employment Law and does not personally offer XXXXX services as acting as executor of estates to the general public and has never acted in such capacity in any other estate. ... You submit that based on the definitions of "taxable supply", "commercial activity", "business", and "office" in subsection 123(1) of the Excise Tax Act (the "ETA"), the definition of "office" in subsection 248(1) of the Income Tax Act, GST Question & Answer #3d.21, and a finding that in the cases of both the freelance bookkeeper and the lawyer the compensation would be income from an office under the Income Tax Act, the fees would not be subject to GST. 7. In your view the position of the CCRA outlined in GST Question & Answer #3d.21 is not clear with respect to the freelance bookkeeper and the lawyer because the bookkeeper was appointed executor due to XXXXX past working relationship with the deceased individual (i.e. ...

XXXXX gives its customers the ability to have their employees, clients and business partners securely access their corporate resources from Internet-enabled devices through secure VPN access and unique SAS (SAS is an acronym for "secure access system") User authentication credentials (e.g., user name and password, digital certificate or security tokens). ... In addition, it is our view that the principal object of the single supply provided by XXXXX under the Agreement is the provision of rights to use software applications that enable the customer to provide its employees, clients and business partners with secure access to its computerized resources. ... Subsection 10(1) of the Place of Supply (GST/HST) Regulations provides, in part, that when a particular supplier makes a supply of Internet access and there is to be one final recipient who acquires it under an agreement either with the particular supplier or another supplier, the supply is made in a particular province if there is a single ordinary location in that province at which the final recipient avails itself of the access, and either: •   the particular supplier maintains information sufficient to determine that location, or •   it is the normal business practice of the particular supplier to obtain information sufficient to determine that location. ...

25 July 1995 GST/HST Interpretation 11660-9- GST Treatment of a Gravity Base Structure Joint Venture Unedited CRA Tags ETA 123; ETA 273                                                                         File 11660-9; 11950-1(sm) Section 123 & 273 Telephone No. (613) 954-8585 Fax No. (613) 990-1233  XXXXX July 25, 1995 Dear Mr. ... Although not mentioned in the joint venture agreement, it is our understanding that the joint venture is also responsible for constructing: •   access roads; •   accommodation for staff; •   all services for the site; •   production facilities for the manufacture of structural steel bars; and •   a wharf at the dry dock site in XXXXX Interpretations Requested 1. ... Subsection 2(1) of that Act contains the following definitions: " 'continental shelf' means the seabed and subsoil of those submarine areas that extend beyond the territorial sea throughout the natural prolongation of the land territory of Canada to the outer edge of the continental margin or to a distance of two hundred nautical miles from the inner limits of the territorial sea, whichever is the greater, or that extend to such limits as are prescribed pursuant to paragraph (2)(a);" " 'federal laws' includes Acts of Parliament, regulations as defined in section 2 of the Interpretation Act and any other rules of law within the jurisdiction of Parliament but does not include ordinances within the meaning of the Northwest Territories Act or the Yukon Act;" " 'marine installation or structure' includes (a) any ship, offshore drilling unit, production platform, subsea installation, pumping station, living accommodation, storage structure, loading or landing platform, dredge, floating crane, pipelaying or other barge or pipeline and any anchor, anchor cable or rig pad used in connection therewith, and (b) any other work or work within a class of works prescribed pursuant to paragraph (2)(b);" Section 5 of that Act provides as follows: "5.(1) Subject to any regulations made pursuant to subsection (2) or (3), federal laws apply (a) on or under any marine installation or structure from the time it is attached or anchored to the continental shelf in connection with the exploration of that shelf or the exploitation of its mineral or other non-living resources until the marine installation or structure is removed from the waters above the continental shelf; (b) on or under any artificial island constructed, erected or placed on the continental shelf; and (c) within such safety zone surrounding any marine installation or structure or artificial island referred to in paragraph (a) or (b) as is determined by or pursuant to regulation. ...

Based on the information provided we understand that you provide the following services to you clients: * Assessment of your clients’ health care needs. * Collaborating with other health care providers in respect of your clients’ care. * Determining appropriate health care services, treatments and equipment. * Counselling clients. * Teaching the families of your clients on how to care for the client. * Analyzing the findings of your clients’ health care assessments. * Providing professional advice. * Providing written reports to your clients’ insurance companies. ... Given the preceding, there are three criteria that the supply must meet to be exempt; i.e., it must be a service that: * is rendered by a registered or licensed nurse; * falls within the scope of nursing services; and * is rendered to an individual within a nurse-patient relationship. ... Some of these activities that would not constitute a nursing service rendered to an individual within a nurse-patient relationship are communicating with communities or populations, managing nursing resources such as staff, facilities and equipment, developing learning resources for nurses or other health care providers, and providing or developing health education for organizations. ...

28 October 1998 GST/HST Ruling HQR0001323- Tax Treatment of English Language Instruction Unedited CRA Tags ETA Sch V, Part III, 11                                                                         GST/HST Rulings and Interpretations  Directorate Place Vanier, Tower C, 10th Floor 25 McArthur Avenue Vanier, ON K1A 0L5 XXXXX XXXXX Case: HQR0001323 Attention: XXXXX October 28, 1998 Subject: GST/HST APPLICATION RULING Tax Treatment of English Language Instruction Dear XXXXX This is in reply to your letter of April 16, 1998, to Revenue Canada in Ottawa on the above-noted subject. ... With respect to the operated primarily requirement, the organization's revenues and human resources should be primarily attributed to the supply of instruction in languages. ...

11 March 1998 GST/HST Interpretation HQR0000734- Regional Municipality of Recycling Operations Unedited CRA Tags ETA Sch V, Part VI, 20(h)                                                                         GST/HST Rulings and Interpretations Directorate Place Vanier, Tower C, 10th Floor 25 McArthur Avenue Vanier, Ontario XXXXX                                                                                 K1A 0L5 XXXXX Case: HQR0000734 XXXXX Business Number: XXXXX Attention: XXXXX March 11, 1998 Subject: GST/HST APPLICATION RULING Regional Municipality of XXXXX Recycling Operations Dear Sirs: Thank you for your letter of June 11, 1997 (and subsequent documentation) concerning the application of the Goods and Services Tax (GST)Harmonized Sales Tax (HST) to the transaction(s) described below. ... To provide information and education activities to promote the conserver [sic] ethic and the attitude that waste is a resource. ...

27 April 1999 GST/HST Ruling HQR0001489- Application of the GST/HST to Business and Financial Transactions for the Hiring of Temporary Workers Unedited CRA Tags ETA 123(1) permanent establishment; ETA 132(3); ETA 142; ETA 165; ETA Sch VI, Part V, 7 GST/HST Rulings and Interpretations Directorate Place Vanier, Tower C, 10th Floor 25 McArthur Avenue Vanier, ON K1A 0L5XXXXX XXXXXAttention XXXXX Case: HQR0001489File #: 11680-7April 27, 1999 Subject: GST/HST APPLICATION RULING Transaction Between XXXXX Dear XXXXX Thank you for your letter of December 2, 1998, received by facsimile, and your subsequent letter dated December 22, 1998, together with the relevant agreements, concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the transaction(s) described below. ... The XXXXX  administrative and management support of this project, including human resource management was and continues to be substantially performed at XXXXX  XXXXX[;] 13. ...

The XXXXX also contributes to Special Projects in various forms, including human resources and funding. ... A "supply" is broadly defined as "... the provision of property or a service in any manner, including sale, transfer, barter, exchange, license, rental, lease, gift or disposition" (All definitions referred to in this ruling are found in subsection 123(1).). ...