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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. ...

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. ...

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. ...

13 March 2000 GST/HST Interpretation 7943/HQR0001549- Supply of Braille Plates for Use With Elevators Unedited CRA Tags ETA Sch VI, Part II, 8; ETA Sch VI, Part II, 30 XXXXX XXXXX XXXXX XXXXXAttention: XXXXX Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 14th Floor 320 Queen Street Ottawa ON K1A 0L5Case: HQR0001549 / 7943March 13, 2000 Subject: GST/HST INTERPRETATION Supply of Braille Plates for Use With Elevators Dear XXXXX This in reply to your facsimile message of January 5, 1999, concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the supply of braille plates for use with elevators. ... As such, only those entities that are registered charities or non-profit organizations whose main objective is to provide services to blind individuals or to act as a consultation or resource agency to the helping professions, government departments and private industry, are bona fide institutions or associations. ...

Resources from both of the supplier's offices have been used in carrying out the terms of the contract. ... The "place of negotiation" is defined in section 1 of Part I of Schedule IX to the ETA to mean "... the location of the supplier's permanent establishment at which the individual principally involved in negotiating for the supplier the agreement for the supply ordinarily works, or to which that individual ordinarily reports, in the performance of the individual's duties in relation to the activities of the supplier in the course of which the supply is made and, for the purposes of this definition, "negotiating" includes the making or acceptance of an offer. ...

. / 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.” ... Based on the application of subsections 141.01(2) and (4), ITCs may be available, subject to the conditions in section 169, to the extent that a person performs a mining activity of validating transactions and adding them to a publicly distributed ledger and: * the person acquired, imported, or brought into a participating province property or services before May 18, 2019; * that property or those services were consumed, used or supplied by the person in the course of validating transactions and adding them to a publicly distributed ledger; * the rewards and transaction fees that would be paid to the person upon success for those mining activities were cryptoassets, such as Bitcoins, that would meet the virtual payment instrument definition in subsection 123(1); and * the person intended, at the time of acquiring, importing or bringing into a participating province the property or service, to acquire the virtual payment instruments as a result of its mining activities for the purpose of supplying those instruments as a commercial activity. ...

PLEASE REFER TO CASE # 35035. Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 14th Floor 320 Queen Street Ottawa, ON K1A 0L5XXXXX XXXXX XXXXXAttention: XXXXX XXXXX Case: 30908September 29, 2000 Subject: GST/HST INTERPRETATION Tax Treatment of the XXXXX Dear XXXXX Thank you for your letter of April 17, 2000, concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the supply of the XXXXX course made by the XXXXX ("the Centre"). ... Human Resources Development Canada certified the Centre as a Certified Educational Institution for the purposes of Section 118.5 and 118.6 of the Income Tax Act, thus entitling the Centre to issue tax receipts for tuition deduction. ... At this point, it is worth noting that the clause in paragraph 9(a), "... or that follows a curriculum designated by, a school authority" refers, in part, to situations where, for lower grades, there may not be course "credits" but there will be a "curriculum. ...

7 May 1998 GST/HST Interpretation HQR0000369- Application of the GST/HST to the Operations of the District Health Board Unedited CRA Tags ETA 123(1), 259(4.1)                                                                         GST/HST Rulings and Interpretations  Directorate Place Vanier, Tower C, 10th Floor 25 McArthur Road Vanier, Ontario XXXXX                                                                                 K1A 0L5 XXXXX Case: HQR0000369 XXXXX                 File: 11880-1 XXXXX May 7, 1998 XXXXX Subject: Application of the GST/HST to the Operations of the XXXXX District Health Board Thank you for your letter of October 18, 1996, concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the operations of the XXXXX (the "Board"). ... Also, the Board is a registered charity and is registered for GST purposes. 3) The Board has one centralized accounting system for all facilities in the XXXXX[.] 4) The Board operates the following facilities: a) The main administrative office for the health district which is involved in centralized payment of bills, purchasing for the facilities within the district, payroll and human resources. b) XXXXX hospitals that provide 24 hour acute care on both an in-patient and out-patient basis, some chronic care, obstetric services, patient accommodation along with both laundry and meal services and ambulance services to the public. ... Vermes             S. Eastman             L. Dixon             J. Crago             N. ...

You have stated that the Charity has a permanent establishment in the following provinces: • Ontario, • Nova Scotia, • British Columbia, • Alberta, • Manitoba, • Saskatchewan, • New Brunswick, • Prince Edward Island, and • Newfoundland and Labrador. ... In most cases, this includes an office, branch, factory, workshop, warehouse, plant, mine, oil well, farm, timberland or natural resource used in the day-to-day activities of the charity. ... The provincial rebate factor for a charity resident in: • Ontario is 82%. • Nova Scotia is 50%. • New Brunswick is 50%. • Newfoundland and Labrador is 50%. • Prince Edward Island is 35%. ...

Included in the XXXXX purpose and objects are: •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX In its financial statements for the fiscal year ending XXXXX, the XXXXX receives the majority of its revenues from the following sources: •   membership fees; •   XXXXX reimbursements; and •   interest income. ... The purpose of this plan is to facilitate the sharing of resources, thus ensuring certainty and stability for the XXXXX and providing for a broader distribution of benefits to XXXXX. ... XXXXX: •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX The Associations were required to pay to the Minister a total of $XXXXX for the XXXXX season. ...