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Unedited CRA Tags ETA Sch V, Part III, 8                                                                         GST/HST Rulings and Interpretations Directorate Place Vanier, Tower C, 10th Floor 25 McArthur Avenue Vanier, ON K1A 0L5 XXXXX Case: HQR0001237                                                                         September 25, 1998 Dear XXXXX This is in response to your letter of November 7, 1997 sent to XXXXX (with attachments), of our XXXXX TIS Center, concerning the definition of vocational school in Part III of Schedule V to the Excise Tax Act (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 the courses that enhance students' occupational skills. ...

STATEMENT OF FACTS Based on your letter, the agreement you have submitted (which is described below), the terms and conditions of the various programs in which you participate, and general information available from online resources, our understanding of the facts is as follows: 1) You are a sole proprietor registered for the GST/HST under business number […]. 2) You operate a video production business […][in Canada] where you produce and post original short videos [through a] web publisher, […] for broadcast on, [(Platform X)]. 3) […][The Web Publisher] is a Canadian […] company incorporated under the laws of […][a province in Canada] and has a principal place of business in […][Canada]. 4) […]. ... [The Web Publisher] is not responsible for remitting any taxes on your behalf. […] g. […] h. ... Sincerely, Kevin Tran Rulings Officer Border Issues Unit 2 General Operations and Border Issues Division GST/HST Rulings Directorate FOOTNOTES 1 […] 2 […] 3 […] 4 […] 5 […] 6 […] 7 […] 8 […] ...

The [Charity]’s home office is located in […][City 1, Participating Province X]. 5. […] [Locations of the Charity’s activities]: * […] * […] * […][Participating Province X] * […][Participating Province Z] […] 6. […] 7. ... First Nations, various provincial Ministries); * infrastructure funding was secured; * signage and gates were erected; * the property was insured; * taxes were paid; * feasibility studies were documented and presented to regional officials; * a […] year lease was drafted; and * […] 11. […] 12. ... 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. ...

Active members are eligible to apply for one of five levels of active membership: Regular Profile, Enhanced Profile Level I, Enhanced Profile Level II, Enhanced Profile Level III and Enhanced Profile Level IV. •   Article 5 of XXXXX indicate that regular active members receive •   a listing on the corporation's web site, •   a link to the member's web site, if any, and •   a listing on some of the corporation's promotional material. •   Article 5 of XXXXX indicate that enhanced active members receive •   a profile on the XXXXX web site and in other promotional material, in accordance with the level of enhanced membership. •   Members selecting enhanced membership may choose to support XXXXX through three levels of "sponsorship": •   According to the Sponsorship Rate Sheet submitted to XXXXX once completed by a sponsor, the rates and benefits of the three levels of sponsorship include:      Category I- $XXXXX and benefits to sponsoring members include: •   the sponsor's company logo and link to the Official Major Sponsors recognition page on XXXXX's home page; •   acknowledgment and logo on the Official Major Sponsor Recognition Page; •   the sponsor's logo (prominently displayed) in the members' directory.      Category II- $XXXXX and benefits include: •   the sponsor's banner on one of a number of XXXXX site features; and •   the sponsor's logo (prominently displayed) in the members' directory.      ... In return, the program sponsor is given recognition in the pamphlet and its logo is included in the pamphlet. •   The terms and conditions set out on the "Sponsorship Rate Sheet" completed by sponsors state: •   all sponsors must be XXXXX members; •   membership and sponsorship commences on the date the application form is received and due yearly thereafter; •   banner location is subject to availability; •   current sponsors retain first right of refusal on location of their banner; •   sponsors are responsible for supplying XXXXX with their own digital logo or banner; •   XXXXX reserves the right to deny membership and sponsorship. ...

During this XXXXX year period, the largest annual operating XXXXX realized by XXXXX ($ XXXXX) amounted to only XXXXX % of its total revenue for that fiscal year. ... "... that was organized...solely for a purpose other than profit... ... " XXXXX has not been given the power to declare or pay a dividend or otherwise distribute its resources among its members. ...

Their current home was purchased for $[…] and the market value had increased to approximately $[…] in [yyyy/yyyy]. 6. ... No assignments were permitted within [#] days of the completion date. ... Put differently, the individual must have the means and resources necessary to acquire the complex for use as a place of residence either for themselves or a relation. ...

XXXXX Ltd. is a major provider of employee services to employers (payroll services, human resources management, benefits administration, etc.). ... These 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 Border Issues Unit General Operations and Border Issues Division Excise and GST/HST Rulings Directorate 2006/01/24 — RITS 63749 — GST Exemption Certificate ...

You have provided and example of one such Partnership Agreement [...] ... In exchange for performing the above services, […] of Agreement #1 generally entitles the Manager to earn from the partnership an annual investment management fee […]. The Manager is also entitled to an annual property oversight fee […], pursuant to […] Agreement #1. ...

XXXXX gives its customers the ability to have their employees, clients and business partners securely access their corporate resources from Internet-enabled devices through secure VPN access and unique SAS (SAS is an acronym for "secure access system") User authentication credentials (e.g., user name and password, digital certificate or security tokens). ... In addition, it is our view that the principal object of the single supply provided by XXXXX under the Agreement is the provision of rights to use software applications that enable the customer to provide its employees, clients and business partners with secure access to its computerized resources. ... Subsection 10(1) of the Place of Supply (GST/HST) Regulations provides, in part, that when a particular supplier makes a supply of Internet access and there is to be one final recipient who acquires it under an agreement either with the particular supplier or another supplier, the supply is made in a particular province if there is a single ordinary location in that province at which the final recipient avails itself of the access, and either: •   the particular supplier maintains information sufficient to determine that location, or •   it is the normal business practice of the particular supplier to obtain information sufficient to determine that location. ...

Based on the information provided we understand that you provide the following services to you clients: * Assessment of your clients’ health care needs. * Collaborating with other health care providers in respect of your clients’ care. * Determining appropriate health care services, treatments and equipment. * Counselling clients. * Teaching the families of your clients on how to care for the client. * Analyzing the findings of your clients’ health care assessments. * Providing professional advice. * Providing written reports to your clients’ insurance companies. ... Given the preceding, there are three criteria that the supply must meet to be exempt; i.e., it must be a service that: * is rendered by a registered or licensed nurse; * falls within the scope of nursing services; and * is rendered to an individual within a nurse-patient relationship. ... Some of these activities that would not constitute a nursing service rendered to an individual within a nurse-patient relationship are communicating with communities or populations, managing nursing resources such as staff, facilities and equipment, developing learning resources for nurses or other health care providers, and providing or developing health education for organizations. ...