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28 October 1998 GST/HST Ruling HQR0001323- 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, ON K1A 0L5 XXXXX XXXXX Case: HQR0001323 Attention: XXXXX October 28, 1998 Subject: GST/HST APPLICATION RULING Tax Treatment of English Language Instruction Dear XXXXX This is in reply to your letter of April 16, 1998, to Revenue Canada in Ottawa on the above-noted subject. ... With respect to the operated primarily requirement, the organization's revenues and human resources should be primarily attributed to the supply of instruction in languages. ...

27 April 1999 GST/HST Ruling HQR0001489- Application of the GST/HST to Business and Financial Transactions for the Hiring of Temporary Workers Unedited CRA Tags ETA 123(1) permanent establishment; ETA 132(3); ETA 142; ETA 165; ETA Sch VI, Part V, 7 GST/HST Rulings and Interpretations Directorate Place Vanier, Tower C, 10th Floor 25 McArthur Avenue Vanier, ON K1A 0L5XXXXX XXXXXAttention XXXXX Case: HQR0001489File #: 11680-7April 27, 1999 Subject: GST/HST APPLICATION RULING Transaction Between XXXXX Dear XXXXX Thank you for your letter of December 2, 1998, received by facsimile, and your subsequent letter dated December 22, 1998, together with the relevant agreements, concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the transaction(s) described below. ... The XXXXX  administrative and management support of this project, including human resource management was and continues to be substantially performed at XXXXX  XXXXX[;] 13. ...

The XXXXX also contributes to Special Projects in various forms, including human resources and funding. ... A "supply" is broadly defined as "... the provision of property or a service in any manner, including sale, transfer, barter, exchange, license, rental, lease, gift or disposition" (All definitions referred to in this ruling are found in subsection 123(1).). ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... Online Resources- With the XXXXX function on XXXXX website, consumers can search online by postal code to find the XXXXX closest to them. ... Yours truly, Nadine Kennedy, CMA Charities, Non-profit Organizations and Educational Services Unit Public Service Bodies and Governments Division Excise and GST/HST Rulings Directorate 2006/04/24 — RITS 64810 — Dried Fruits ...

" * […] [Details of Agreement A] 11. Pursuant to [Agreement A] […]. 12. ... [The Charity] entered into […] [Agreement B], dated [mm/dd/yyyy], with […] [Participating Province Y] […]. 16. […]. 17. […] [Details relevant to Agreement B] 18. […] [Details relevant to Agreement B] 19. ... 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. ...

As part of its mandate, the OPA contracts with electricity generators for clean electricity resources. ... A positive GA cannot be considered a price adjustment under subsection 232(2) because the wording refers to “… the consideration or part is subsequently reduced …”. ... British Columbia (Interior Tree Fruit & Vegetable Committee of Direction 6 and Eurig Estate v. ...

Most of the Association’s operating costs are incurred in [Province 1]; however, […] costs are also incurred in other provinces throughout the year. 13. […] you indicated that the [responsibilities of the] Association’s employee who is working from [City 2] […] include: * preparing meeting minutes; * making arrangements to set up meetings; * looking after Association’s […] and corporate filings; * providing support to the Association’s VP in [City 1], as well as providing support to the CEO; * verifying accuracy of the expense claims; * negotiating with hotels when arranging for meetings, etc. 14. […] you also confirmed that the Association does not have a dedicated office space for the employee working in [City 2] and that employee is working from home. ... With respect to the expenses incurred by the Association outside of [Province 1], you provided the following examples of the types of expenses that the Association incurs in other provinces: * expenses incurred in connection with conferences intended to provide education to […][attendees]; the location for these conferences changes from year to year; * attending meetings in other cities outside of [Province 1]; * travel expenses incurred by Board Members (the Board of Directors has members from […][across] Canada); * [other] travel expenses […]. ... 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 Agreement), a sample contract from [...], a contract between [...] and [...], a contract between [...] and [...] and our telephone discussion of March 21, 2011, that: 1. [...] ... In [...] [Participating Province X], the Mortgage Broker is licensed with [...]. 3. ... They have access to brand and resources of the Mortgage Broker for this purpose and are acting on behalf of the Mortgage Broker when assisting borrowers in obtaining residential mortgages. ...

On [mm/dd/yyyy], the Assignor and […](the Vendor) entered into an Agreement of Purchase and Sale ([…][the Agreement]) with respect to a residential condominium unit (the Unit) legally described as: […] with a municipal address of […]. 5. ... According to the Assignment Agreement: a) the Assignee was required to pay, to the Assignor, an assignment amount of $[…] for the assignment of [the Assignor’s] rights in [the Agreement]. […][An amount of]$[…] was payable [by the Assignee to the Assignor] as a deposit and the remaining balance of $[…] was payable [to the Assignor] on the Completion Date; b) the Assignee was required to pay, to the Developer, an assignment fee of $[…] plus [GST/HST]; c) the assignment amount included an amount to reimburse the Assignor for the Deposit of $[…] that was paid upon execution of [the Agreement] thus, the Assignor’s profit before commissions was $[…] (that is, $[…]- $[…] = $[…]); d) the Assignor was responsible for paying, to the Sub-agent, both the listing and selling agent portions of the commission in respect of the assignment of the Assignor’s rights in [the Agreement], which was a total of $[…] thus, the Assignor’s profit after commissions was $[…] (that is, $[…]- $[…] = $[…]); and e) the assignment amount (that is, $[…]) was inclusive of any [GST/HST] payable with respect to the assignment of the Assignor’s rights in [the Agreement], and the Assignor must remit any [GST/HST] payable. 13. ... 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. ...

Our facts were taken from the following documents and telephone conversations: •   your letter dated December 20, 1995, addressed to the XXXXX Tax Services Office, Revenue Canada; •   your letter dated April 17, 1996, addressed to XXXXX Tax Services Office, Revenue Canada; •   the subcontract agreement, XXXXX, between XXXXX and XXXXX that was attached to your letter of April 17, 1996, including XXXXX to the subcontract; •   a copy of the GST Application Ruling XXXXX dated April 29, 1996, that was issued by XXXXX Tax Services Office, Revenue Canada; •   your letter dated May 15, 1996, addressed to the XXXXX Tax Services Office, Revenue Canada; •   a copy of the GST Interpretation (XXXXX dated July 14, 1997, that was issued by C XXXXX Region, Revenue Canada; •   your letter dated July 17, 1997, addressed to XXXXX Revenue Canada; •   a copy of the Project Summary Sheet attached to your letter of July 17, 1997; •   a revised Statement of Work XXXXX to XXXXX received by facsimile transmission on September 23, 1997; •   a telephone conversation on October 7, 1997, between XXXXX Region and yourself; and •   our telephone conversation of January 8, 1998. ... In your letter of July 17, 1997, you provide further clarification to the language used in the Statement of Work. •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX 18. ... As Intellectual Property Rights to some of your earlier methanol ignition system work are held by the Government of Canada, through the Ministry of Natural Resources, you felt that it was germane that the wording of the Statement of Work would make it perfectly clear that XXXXX did not, as a result of the contract, gain any property rights to any proprietary information used in the design and application of the research program. ...