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LUAC is an educational institution that is certified by the Minister of Human Resources and Development (formerly, Minister of Employment and Immigration) for purposes of subsection 118.5 of the ITA and so, prior to 1997, it met the definition of vocational school in the ETA. ... Rather, the Department will look to the organization as a whole and consider a number of factors, such as whether more than 50% of the revenue, expenses, and human resources of the organization are in respect of the provision of correspondence courses or instruction in courses that develop or enhances students' occupational skills. ... Further, the measure of human resources is indeterminate as it does not wholly relate to the instruction in of courses, but also includes time related the preparation and distribution of publications. ...

Ruling Requested •   Under our policy, do the above organizations fall within the meaning of "vocational school" as described in section 1 of Part III of Schedule V to the ETA? •   Is it our view that courses supplied by the above organizations are exempt under sections 6 or 8 of Part III of Schedule V to the ETA? ... Further, with respect to the operated primarily requirement, most of the organization's revenue and human resources should be attributed to the provision of courses that enhance students' occupational skills. ...

29 June 1998 GST/HST Interpretation HQR0000217- Damage Claims Unedited CRA Tags ETA 182(1)                                                                         GST/HST Rulings and Interpretations   Directorate Place Vanier, Tower C, 10th Floor 25 McArthur Avenue Vanier, Ontario XXXXX                                                                                 K1A 0L5 XXXXX Case: HQR0000217 XXXXX                 File: 11735-1 Ss. 182(1) XXXXX June 29, 1998 Subject: GST/HST INTERPRETATION Damage Claims Dear XXXXX Thank you for your facsimile transmission of May 28, 1996 concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to your operations. ... When this occurs, the telephone company that owns the cable would perform the necessary repairs using its own resources and invoice the party or parties responsible for the damages. 3. ... These situations could include: •   no prior agreement for a taxable supply existed between the parties; •   the payment is being made by the supplier of the original supply; •   the original supply was not made by a registrant; or •   the payment is actually additional consideration for the original supply. ...

Your letter states: "[...] [Pursuant to] GST Memorandum 1.4: Excise and GST/HST Rulings and Interpretations Service, [...] [ACo] request[s] a GST interpretation on [...] the application of subsection 188(1) of the Excise Tax Act (the "ETA") to prize winnings [...] [distributed] to customers who participate in a game of chance [...] [ACo]conducts on a periodic basis to promote the sale of GST taxable items. [...] ...

Supplies Made During 1996 Prior to January 1, 1997, the definition of "vocational school" in section 1 of Part III of Schedule V to the Excise Tax Act ("section 1") included an organization that met one of the following two conditions: •   Established and operated primarily to provide courses that develop or enhance students' occupational skills; or •   Certified by the Minister of Employment and Immigration (now Human Resources Development) for the purposes of the tuition tax credit under subsection 118.5(1) of the ITA. ... It is our position that the following programs develop or enhance students' occupational skills: •   Commercial Pilot Licence (Aeroplane); •   Airline Transport Pilot Licence; •   VFR Over-the-Top rating; •   night rating; •   multi-engine rating; •   instrument flight rating; •   sea plane rating; •   land plane rating; and •   flight instructor ratings. ... (d) Classes or Ratings in Respect of Pilots' Licences The solo and dual flight time required by federal legislation for the following ratings is exempt under section 8: •   multi-engine rating •   instrument flight rating •   VFR Over-the-Top rating •   night rating •   sea plane rating •   land plane rating •   flight instructor rating (Please note however that the build-up time component for flight instructor ratings is a taxable supply.) ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... Furthermore, XXXXX Human Resources Policy XXXXX, a copy of which you have provided XXXXX XXXXX 8. ... Yours truly, Patricia Taylor, CMA General Operations Unit General Operations & Border Issues Division Excise and GST/HST Rulings Directorate 2006/02/07 — RITS 77859 — [ITC for Tax on Imported Goods] ...

14 October 1998 GST/HST Ruling HQR0000761- Tax Treatment of English Language Instruction Unedited CRA Tags ETA Sch V, Part III, 11; ETA 123(1) school authority; ETA 123(1) public college; ETA 123(1) university                                                                         GST/HST Rulings and Interpretations  Directorate Place Vanier, Tower C, 10th Floor 25 McArthur Avenue Vanier, ON K1A 0L5 XXXXX Case: HQR0000761 XXXXX Attention: XXXXX October 14, 1998 Subject: GST/HST APPLICATION RULING Tax Treatment of English Language Instruction Dear XXXXX This is in reply to your letter of December 10, 1995, to Revenue Canada in Ottawa on the above-noted subject. ... The courses may include the following activities: •   Group instruction in seasonal sports, such as tennis, swimming, sailing, canoeing, cross-country and downhill skiing and skating; •   Group singing and Canadian folk songs; •   Games, bowling and movie evenings; and •   Field trip to XXXXX[.] 5. ... With respect to the operated primarily requirement, the organization's revenue and human resources should be primarily attributed to the supply of instruction in languages. ...

Ruling Requested DIAND is required to charge GST on the supplies it provides, as described XXXXX Schedules I and II to the Territorial Land Use Regulations [.] DIAND is required to charge GST on the supplies it provides, as described in XXXXX Schedule to the Territorial Lands Regulations [.] DIAND is required to charge GST on the supply of a right to enter federal real property, as provided for through a Licence agreement, made pursuant to the Federal Real Property Regulations [.] ...

25 September 1998 General Information Letter HQR0000981- GENERAL INFORMATION LETTER Tax Treatment of French 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, Ontario K1A 0L5 XXXXX XXXXX HQR0000981 XXXXX                 September 25, 1998 K1A 0K9 Subject: GENERAL INFORMATION LETTER Tax Treatment of French Language Instruction Dear XXXXX This is in reply to your facsimile message of December 11, 1997, to Ms. ... With respect to the operated primarily requirement, most of the organization's revenue and human resources should be attributed to the supply of instruction in languages. ...

25 September 1998 General Information Letter HQR0000997- GENERAL INFORMATION LETTER 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, Ontario K1A 0L5 XXXXX Case No. ... With respect to the operated primarily requirement, most of the organization's revenue and human resources should be attributed to the supply of instruction in languages. ...