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This would require twice the resources and extra cost, the benefit of which would be lost on the system to be replaced. 9. ... Yours truly, Carolle Mercier Services and Intangibles Unit General Operations & Border Issues Division Excise and GST/HST Rulings Directorate ...

25 April 1997 GST/HST Interpretation HQR0000296[2]- Non-Resident Permanent Establishment and Security Requirement Unedited CRA Tags ETA 123(1); ETA 132(2); ETA 240(6)                                                                         File 11680-4(RMcK)                                                                         April 25, 1997 Gareth Llewellyn GST Policy & Procedures Policy, Procedures & Systems Business Registration Section Subject: Non-Resident Permanent Establishment and Security Requirement I refer to your E-mail message of September 19, 1996 concerning non-resident Permanent Establishment (PE) and changes to the security requirements. ... General Comments Section 123 of the Act defines the term "permanent establishment" to be the fixed place of business, including a place of management, branch, office, factory, workshop, mine, oil or gas well, quarry, timberland, or other place of extraction of mineral resources through which supplies are made. ...

11 September 1998 GST/HST Interpretation HQR0001263- Your File: Lease or Licence Unedited CRA Tags GST/HST Policy Statement P-062, Distinction Between Lease, Licence and Similar Arrangement                                                                         GST/HST Rulings and Interpretations                                                                                                 Directorate                                                                                                 Place Vanier, Tower C, 10th Floor XXXXX                                                                                 McArthur Road XXXXX                                                                                 Vanier, Ontario XXXXX                                                                                 K1A 0L5 XXXXX Case: HQR0001263 File 11895-1, 11950-1 Attention: XXXXX September 11, 1998 Subject: GST/HST INTERPRETATION Your File XXXXX: Lease or Licence Dear XXXXX Thank you for your letter of July 22, 1998 (with attachments) concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to a contract to operate food concessions at various municipally owned venues. ... In any event, the tender documents indicate that the successful bidder for the contract was to have certain minimum levels of experience and resources. ... Yours truly, Michael Ezri A/Rulings Officer Real Property Unit Financial Institutions & Real Property Division GST/HST Rulings and Interpretations Directorate ...

Under the agreement, XXXXX undertakes to provide to XXXXX "human resources services in relation to XXXXX employees. ... The factors that will be considered in determining whether a non-resident person is carrying on business in Canada for GST/HST purposes in a particular situation 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 Senior Rulings Officer Border Issues Unit General Operations and Border Issues Division Excise and GST/HST Rulings Directorate 2005/07/22 — RITS 56334 — Supplies Made Via the Internet ...

You referred to the "Brain Aneurysm Resources" Internet Website at [http://www.brainaneurysm.com/aneurysm-treatment.html] for more information. ... Ruling Requested You are requesting that supplies of the following medical products made by XXXXX fall within section 25 of Part II of Schedule VI and thus are zero-rated supplies: •   Fabrics and patches; •   Peripheral grafts and abdominal/thoracic grafts; •   Detachable coils; and •   Embolic agents. Ruling Given The supplies of the following medical products made by XXXXX fall within section 25 of Part II of Schedule VI: •   Fabrics and patches; •   Peripheral grafts and abdominal/thoracic grafts; and •   Detachable coils. ...

. / Veuillez prendre note que ces documents, bien qu'exacts au moment émis, peuvent ne pas représenter la position actuelle de l'Agence. ... For purposes of this interpretation request, it is assumed that the requirement under paragraph 191.1(2)(b) is met.) •   The builder is not a government or municipality; •   The builder is a private non-profit or charitable organization. ... Section 191.1 deems the amount of tax resulting from the self-supply to be the greater of 7% GST or 15% HST on the fair market value of the residential complex and the tax paid on the acquisition of the land, on the construction of the building, and on any improvements to the property, where: •   government funding in respect of a complex is paid or payable to a builder of the complex or of an addition thereto; •   the builder is deemed under any of subsections 191(1) to (4) to have, at any time, made and received a supply of the complex or addition thereto; •   at least 10% of the residential units in the complex are intended to be supplied to individuals referred to in paragraph 191.1(2)(b); and •   the builder, at or before that time, has received or can reasonably expect to receive government funding in respect of the complex. 1. ...

In the course of the joint venture activities, […] are payable by the […] of the joint venture. The payments by […] are made to the account of the nominee corporation. 9. ... Yours truly, Ken Syer Manager Goods Unit General Operations and Border Issues Division Excise and GST/HST Rulings Directorate     ...

The public purpose of the contributions is reflected throughout the guide on The XXXXX The four main objectives of the program, as described in the guide, are: •   to introduce the concept and ensure the commitment of long-term, ongoing training. •   to support training initiatives that will lead to measurable economic growth such as increase productivity. •   to support participative management of training between management and labour through the establishment of "Boards and Trustees" who together participate in the planning, development and delivery of long-term training. •   to provide seed money to establish and finance necessary long-term employment related training and re-training which would add to or accelerate an organization's current training initiatives. ... " and to provide "an opportunity for workers and employers to establish resources for training and retraining... ... These responsibilities include the requirement to: •   determine usage and application of funds from the trust and formulate an annual training plan •   ensure that contributions by the employees/employers or on behalf of the employees, are made •   maintain a separate bank account for all provincial contributions and corresponding contributions to the trust •   maintain accurate and up-to-date records and documentation as required by the XXXXX such as invoices for expenditures related to the training plan •   submit quarterly reports to the XXXXX identifying the amount of contributions made to the XXXXX by the employees and/or employers, the amount and type of training conducted and the number of employees participating in the training as compared with the approved training plan. ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... Where the person takes water from a government resource such as a lake or river, a copy of a permit or other evidence allowing the person to take such water to sell or other satisfactory evidence that the person has ownership of the water, such as a letter from a municipality describing how the water is made available to the person free of charge. ... Yours truly, Susan Eastman Municipalities and Health Care Services Unit Public Service Bodies and Governments Division Excise and GST/HST Rulings Directorate 2007/12/10 — RITS 100391 — 24 x XXXXX ml XXXXX Green Tea XXXXX- XXXXX ...

. / 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. Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5 [Addressee] Case Number: 158436 Dear [Client]: Subject: GST/HST INTERPRETATION Election concerning the acquisition of a business or part of a business Thank you for your letter in which you provided comments on the “Supply of business assets” portion of draft GST/HST Memorandum 3.7, Natural Resources. ... Yours truly, William Parker Special Provisions – FI Unit Financial Institutions and Real Property Division Excise and GST/HST Rulings Directorate ...