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16 July 1998 GST/HST Ruling HQR0000930- Application of the GST/HST to the Reimbursement of Salaries and Benefits Paid by Canada to an Officer Temporarily Assigned to Natural Resources Canada                                                                         GST/HST Rulings and Interpretations Directorate Place Vanier, Tower C, 10th Floor 25 McArthur Avenue Vanier, Ontario K1A 0L5 Natural Resources Canada 580 Booth Streeet, 4th Floor Ottawa, Ontario Case: HQR0000930 K1A 0E4               Business Number: XXXXX Attention: XXXXX, Corporate Accounting July 16, 1998 Subject: GST/HST APPLICATION RULING XXXXX XXXXX Dear XXXXX Thank you for your letter of October 23, 1997 (with attachments) concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the transactions described below. ... Natural Resources Canada, XXXXX entered into an XXXXX dated XXXXX under which XXXXX was assigned by XXXXX to Natural Resources Canada. ... Natural Resources Canada, and XXXXX entered into an XXXXX dated XXXXX under which XXXXX was assigned by XXXXX to Natural Resources Canada. ...

According to […], “[the Corporation] is the independent, non-profit organization that […]. ... The Charity has the expertise, experience and resources to carry out the activities described above and within the Master Agreement. 7. ... The Charity has the expertise, experience and resources to carry out the activities described within the Master Agreement. 16. ...

The Program is undertaken by [...]. The [Corporations] do not contribute resources or personnel under the Program. 4. ... Article [...] of the Agreement, states that [...] 6. The Insurance [...] ... Typically, the sequence of events is as follows: • [The Company] salesperson [...] closes a sale [...]. • [The Company] salesperson then asks the [...] ...

12 December 2017 GST/HST Ruling 176138- – Law enforcement services Unedited CRA Tags ETA 123; ETA Sch V, Part VI, 20(g) Please note that the following document, although correct at the time of issue, may not represent the current position of the Canada Revenue Agency. / 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. ... In our view, [Municipality A] has not made an exempt supply of law enforcement services as described in paragraph 20(g) of Part VI of Schedule V, but rather a supply of personnel or human resources. ... Yours truly, Marlon Latchana Senior Rulings Officer Municipal Sectors Unit Public Service Bodies and Governments Division Excise and GST / HST Rulings Directorate ...

Corporation offers its services [...] 6. The staff at Corporation includes [...]. 7. ... [Activity B] includes [...] 23. Priority to attend [Activity B] is given to clients of Corporation who [...] need further development [...]. ... Often, the children who participate in this program come from a home environment with fewer resources and wouldn't otherwise have the opportunity to experience the types of activities and instruction offered at [Activity B]. 27. [...] ...

The following information concerning a deemed supply of a specified resource made under subsection 172.1(5) is required for purposes of subsection 172.1(8) above. • The name of the employer and business number, if applicable. • The name of the pension entity and corresponding pension plan number. • A description of the specified resource sufficient to identify it and the date that the employer acquired it. • The fair market value ("FMV") of the specified resource. • The federal part (viFootnote 6) of the deemed tax paid on the deemed taxable supply of the employer resource (FMV of specified resource × 5%). • Where the pension entity is not an SLFI, the provincial part (viiFootnote 7) of the deemed tax paid on the deemed taxable supply of the employer resource (FMV of specified resource × sum of the relevant provincial factors). • Where the pension entity is not an SLFI, the provincial factors (viiiFootnote 8) used to calculate the provincial part of HST. The following information about a deemed supply of an employer resource made under subsections 172.1(6) and (7) is required for purposes of subsection 172.1(8) above. • The name of the employer and business number, if applicable. • The name of the pension entity and corresponding pension plan number. • A description of the employer resource sufficient to identify it. • The federal part of the deemed tax paid on the deemed taxable supply of the employer resource (multiply the following three items): • the fair market value ("FMV") of the employer resource, • the extent (expressed as a percentage) to which the employer (during times in the fiscal year when the employer was both a registrant and a participating employer) consumed or used the employer resource during the fiscal year for the purpose of making the pension supply, and • The GST or federal part of HST. • Where the pension entity is not an SLFI, the provincial part of the deemed tax paid on the deemed taxable supply of the employer resource (multiply the following three items): • the fair market value ("FMV") of the employer resource, • the extent (expressed as a percentage) to which the employer (during times in the fiscal year when the employer was both a registrant and a participating employer) consumed or used the employer resource during the fiscal year for the purpose of making the pension supply, and • the provincial factor. 2. ... Yours truly, Paul Hawtin Specialty Tax Unit Financial Institutions and Real Property Division Excise and GST/HST Rulings Directorate i 1 [...] ii 2 [...] iii 3 Note that if the employer resource was consumed during the fiscal year for the purpose of making the pension supply, the FMV of the employer resource is determined at the time the employer began consuming the employer resource in the fiscal year. ...

Statement of Facts Based on your submissions we understand the following: [...] ... (the "Plan"), a statutory pension plan of [...] [Participating Province X] established under the [...] ... Explanation Under section 172.1, an employer that is a GST/HST registrant and a participating employer of a pension plan may be deemed to have made a taxable supply where, at any time in a fiscal year of the employer, the employer: • acquires a particular property or a service (a specified resource that is not excluded resource) for the purpose of re-supplying some or all of that property or service to a pension entity for consumption, use or supply in the course of pension activities of the pension plan; • consumes or uses an employer resource that is not an excluded resource for the purpose of making a supply of property or a service to a pension entity for consumption, use or supply in the course of pension activities in respect of the pension plan; and • consumes or uses an employer resource that is not an excluded resource in the course of pension activities and the consumption or use is not for the purpose of making a supply of property or a service to the relevant pension entity. ...

In other words, the parent is provided the opportunity to submit a […] resource, [an external program provider] to the School. ... The parent would choose […][the Program] as the resource that meets the needs of their child. […][The Program] offers […]. ... Once a […] term is completed, the student begins a new […] term with new activities. ...

SLPs work in a variety of health and educational settings, such as: •   Hospitals, •   Public health units, •   Community health centres, •   Schools, •   Children's treatment centres, •   Community Care Access Centres, •   Private practice, •   Preschool settings and daycare centres, •   Resource centres, •   Facilities for developmentally or physically challenged individuals, and •   Nursing homes and long-term care facilities. You indicated that the duties of an SLP include the following: •   Administering tests and examinations and observing patients to diagnose and evaluate speech, voice resonance, language, cognitive linguistic and swallowing disorders. •   Planning and implementing remedial programs to correct speech, language and voice disorders. •   Establishing group and personalized care plans working as a member of an interdisciplinary team. •   Conducting research on speech and other communication disorders and on the development and design of diagnostic procedures and devices. •   Instructing students and other personnel. ... Yours truly, Susan Eastman Municipalities and Health Care Services Unit Public Service Bodies and Governments Division 2004/11/02 — RITS 50061 — Services Supplied by XXXXX [Instructors and Therapists] ...

Hydro. 2. […] (the Engineer) evaluates locations for their potential to produce electricity. ... Under the Agreement, Company A agrees to pay various fixed amounts payable at different stages and a royalty of not less than […]% and a maximum of […]% that is payable under the terms of the Royalty Agreement. 5. ... Payments made to the Engineer pursuant to the Agreement are not computed by reference to the production from a natural resource as required by this paragraph. ...