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GST/HST Interpretation

17 June 2024 GST/HST Interpretation 203070 - Application to Bitcoin Mining and the Sale of Bitcoins

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence du revenu du Canada. ... A ”mining activity” is defined in subsection 188.2(1) to mean “an activity of (a) validating transactions in respect of a cryptoasset and adding them to a publicly distributed ledger on which the cryptoasset exists at a digital address; (b) maintaining and permitting access to a publicly distributed ledger on which a cryptoasset exists at a digital address; or (c) allowing computing resources to be used for the purpose of, or in connection with, performing activities described in paragraph (a) or (b) in respect of a cryptoasset.” ... Subsection 188.2(5) provides an exclusion to subsection 188.2(2) to (4) to the extent that the mining activity is performed by a particular person for another person if (a) the identity of the other person is known to the particular person; (b) where the mining activity is in respect of a mining group that includes the particular person, the other person is not a mining group operator in respect of the mining group; and (c) where the other person is a non-resident person and is not dealing at arm’s length with the particular person, each property or service being property or a service that is received by the other person from the particular person as a consequence of the performance of the mining activity is supplied, or is used or consumed in the course of making a supply, by the other person to one or more persons each of which (i) is a person whose identity is known to the other person, (ii) deals at arm’s length with the other person, and (iii) is not a mining group operator in respect of a mining group that includes the other person if the mining activity is in respect of that mining group.” ...
GST/HST Interpretation

2 December 2014 GST/HST Interpretation 164212 - Eligibility to make the election under section 273

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence du revenu du Canada. ... As stated in the policy statement a “participant” means: (a) a person who, under a joint venture agreement evidenced in writing, makes an investment by contributing resources and takes a proportionate share of any revenue or incurs a proportionate share of the losses from the joint venture activities; or (b) a person, without a financial interest, who is designated as the operator of the joint venture under an agreement in writing and is responsible for the managerial or operational control of the joint venture. ...
GST/HST Ruling

4 August 2010 GST/HST Ruling 115852 - Application of GST/HST to the Supply of Nursing Personnel to Health Care Facilities Located in XXXXX

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... This method of calculating the consideration for the supply (i.e., an hourly rate based on the qualifications of the personnel) does not suggest a 'fee for nursing services', but rather it is indicative of a supply of personnel or human resources. ... The nature of XXXXX business provides a context that is consistent with the position that the supply made by XXXXX pursuant to the Agreement is that of personnel or human resources. ...
GST/HST Interpretation

10 August 2011 GST/HST Interpretation 129131 - Supply of nurses to a hospital

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence du revenu du Canada. ... Where, in accordance with an agreement between the Company and a hospital, the Company's responsibility is limited to providing registered or licensed nurses to the hospital on an as-needed basis so that the hospital may satisfy its own staffing requirements, and the nurses are subject to the control of the hospital and render services under the direction of the hospital in accordance with the hospital's responsibility to provide care to an individual, it is likely that the Company is making a supply of personnel or human resources, and not a supply of nursing services. ... In this situation, the supply of the personnel or human resources by the Company does not fall within section 6 of Part II of Schedule V and, therefore, is generally taxable for GST/HST purposes. ...
GST/HST Interpretation

7 May 1998 GST/HST Interpretation HQR 367 - Health Districts in

The facilities are identifiable by separate account numbers in their general ledger and are treated as separate cost centres for financial reporting. 7) The Board operates the following facilities: a) the district's main administrative office which handles the payment of bills, purchasing for the health facilities within the district, payroll and human resource services. b) three hospitals that provide 24 hour acute care, minor surgery and post surgical and medical care, in and out-patient care and chronic care. ... These two facilities were converted again to nursing homes providing accommodation, meals and 24 hour long-term care to residents requiring personal care. f) XXXXX nursing homes providing accommodation, meals and 24 hour long-term care to residents. g) ambulance services provided by private ambulance operators contracted to the district. 8) The Board's total revenue for the year ending March 31, 1996, was approx. $16 million and included revenue from the following supplies: •   cafeteria sales from the facilities located within the district including meals on wheels sales to residents of the nursing homes. •   meals sold to employees. •   coin operated vending machines dispensing carbonated beverages. •   electricity provided to employees for plugging cars in winter. •   charges to employees for using photocopiers and fax machines for personal use. •   television rentals to patients. •   sale of medical supplies like incontinence products and other supplies such as Kleenex to patients at the health care facilities. 9) The Board is not registered for GST purposes and has not collected the GST on any of its supplies. ... (b) & (c) You have asked whether the Board's registration should be backdated to the date it exceeded the small supplier threshold and, if so, should the Board be assessed retroactively. ...
GST/HST Ruling

28 February 2023 GST/HST Ruling 205313 - Computer hosting services to non-residents and drop-shipment rules

[NonResCo] employs [#] persons located […][outside of Canada]. 3. [NonResCo] […] is contemplating […][establishment of] a Canadian corporate subsidiary. 4. ... [NonResCo] […] anticipates, most customers will be engaged in cryptoasset mining. 6. ... The mining equipment may loosely be described as [cryptoasset mining] computer equipment and includes, generally speaking, […]. 12. ...
GST/HST Interpretation

2 November 1995 GST/HST Interpretation 11894-7 - Clarification as to Whether the Management Bodies Established by Under Qualify to be Determined to be Municipalities for GST Purposes as "Special Purpose Provincially or Territorially Established Authorities" as Outlined in Technical Information Bulletin B-046 Published by Revenue Canada

XXXXX 1) Pursuant to XXXXX (the "Act"), XXXXX may "provide advisory, financial and other support and resources to persons, develop and support the development of housing accommodation, enter into agreements with the government of another jurisdiction or any person, or do any other thing not mentioned above" to enable the efficient provision of a basic level of housing accommodation for persons who because of financial, social or other circumstances require assistance in obtaining or maintaining housing accommodation. 2) Section 1 of the Act defines "housing accommodation " to mean buildings or units in buildings that are suitable and adequate for human habitation, including services that may be provided to residents of the buildings or units because of their circumstances, and includes lodge accommodation. 3) Section XXXXX of the Act defines "lodge accommodation" to mean a home for the use of senior citizens who are not capable of maintaining or do not desire to maintain their own home, including services that may be provided to them because of their circumstances. 4) Pursuant to subsection XXXXX of the Act XXXXX establish management bodies to operate and administer housing accommodation which includes lodge accommodation. ... The same applies to an existing corporation that is established as a management body. 7) Under the provisions of section XXXXX of the Act, the province may direct a management body to take appropriate action if it determines that the affairs of the management body are being managed in an improper manner. 8) The province may rescind an order establishing a management body pursuant to section XXXXX of the Act. 9) Pursuant to section XXXXX of the Act the management body is required to appoint one or more auditors for the management body who must report to the board of the management body on the annual financial statements of the body and pursuant to section XXXXX the management body is required to prepare and present its annual financial statements to the province and any municipality that is required to contribute funding to support the housing. 10) Pursuant to section XXXXX of the Act the province may make regulations: •   respecting the type and amount of financial assistance it may make with respect to housing accommodation, •   respecting the management and operation of management bodies and the manner in which they are to exercise their powers, functions and carry out their duties, •   respecting eligibility requirements of tenants in housing accommodation, •   prescribing the rent and other charges or the manner of determining the rent or other charges that may be charged in respect of a tenancy in housing accommodation, •   governing the termination of tenancies, the terms and conditions that apply to tenancy in a housing accommodation, and •   prescribing additional activities that a management body may carry on and governing the manner in which it is to carry on those activities. 11) The appendix of a sample of a ministerial order creating a management body that we reviewed indicates that the management body is responsible for the operation and administration of housing accommodation, and for purposes of XXXXX the management body is subject to the regulations mentioned in B,C and D outlined below. ...
GST/HST Ruling

10 August 2011 GST/HST Ruling 126175 - Application of GST/HST to services of performing artists supplied by a charity

In [Participating Province X], teachers are responsible for developing appropriate instructional strategies to help students achieve curriculum expectations and may utilize a variety of resources and approaches to support student learning. ... (d) [...] [The Organization] supplied the services of [...] [(Performer 3)] to provide [...] performances [...], on [mm/dd/yyyy], to [...] ... -minute demonstration workshop of [...] on [mm/dd/yyyy], to [...] School, for [...] students in grade [...]. ...
GST/HST Ruling

20 March 2017 GST/HST Ruling 160594 - and INTERPRETATION - Services provided for children in care of a province

You were a self-employed sub-contractor working with […] ([…][Company A]), based in […][City 1], Alberta. ... You are registered for GST/HST purposes with account number […] 3. You are not a social worker. 4. ... Some supplies are exempt from the GST/HST that is, no GST/HST applies to them. ...
GST/HST Interpretation

6 July 2021 GST/HST Interpretation 206211 - Assignment of an agreement of purchase and sale of a condominium unit

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence du revenu du Canada. ... The Assignor purchased the condo approximately [#] years ago ([yyyy]). ... Put differently, the individual must have the means and resources necessary to acquire the complex prior to the change in financial regulations. ...

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