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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 ...

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 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 ...

. / 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. ... The Company has [#] employees in Canada and a Canadian subcontractor (herein the "Canadian Staff"). ... Pursuant to subsection 123(1) of the ETA a "permanent establishment", in respect of a particular person, means (a) a fixed place of business of the particular person, including (i) a place of management, a branch, an office, a factory or a workshop, and (ii) a mine, an oil or gas well, a quarry, timberland or any other place of extraction of natural resources, through which the particular person makes supplies, or (b) a fixed place of business of another person (other than a broker, general commission agent or other independent agent acting in the ordinary course of business) who is acting in Canada on behalf of the particular person and through whom the particular person makes supplies in the ordinary course of business; GST/HST Policy Statement P-208R: Meaning of "Permanent Establishment" In Subsection 123(1) of the Excise Tax Act (a copy may be attained at http://www.cra-arc.gc.ca/E/pub/gl/p-208r/README.html), sets out various factors to consider in determining whether a person has a permanent establishment under subsection 123(1) of the ETA, and more specifically, whether there is a fixed place of business in Canada of the person or that of another person described in the provision. ...

This transfer is actioned through an Order-in-Council. 2) A copy of the Order-in-Council that originally transferred XXXXX has not been provided. 3) XXXXX "To facilitate the mobility of people and goods on the municipal road network; an essential component of the province's transportation system, by: 1) Distributing provincial transportation funds and technical assistance to all municipalities. 2) Allocating of subsidies in accordance with local needs and resources. 3) Supporting the growth of local industries by assisting with the financing and upgrading of the existing road systems. ... (See item number 9.) 7) Pursuant to MTO's policy 9.5.2 "Connecting links are defined as: •   A route that connects the ends of a highway by the most direct, practical means from one municipal boundary to another. •   A route that connects the end of a highway to another highway entering a municipality. •   The extension of a highway from a municipal boundary to the central business district of the municipality or to connect with a Provincial or International boundary. ... Venne Director Tax Policy- Special Sectors             M. Viger Manager- Governmental Sectors             Donna Harding Policy Officer ...

It further provides that the transportation consortium will manage and administer all home-to-school-to-home transportation, school-to-school transportation, and special needs transportation within the Boards' jurisdiction. d) Subparagraph [...] requires the transportation consortium to enter into common contracts with transportation service providers. e) Paragraphs [...] provide for the supervision of the transportation consortium by a management committee (CMC). [...]. The day to day management of the transportation consortium would be provided by a General Manager. [...]. f) Paragraph [...] mandates the transfer of each Board's transportation staff to the transportation consortium. [...]. g) Paragraph [...] provides that the costs associated with the management of the affairs of the transportation consortium and the cost responsibilities of each Board shall be as set out in Schedule [...]. h) Paragraph [...] confirms that the transportation consortium shall provide transportation services in accordance with the Boards' transportation policies. ... It further provides that [...]. l) The remainder of Schedule [...] to the agreement sets out the formulae to be used to calculate each Board's share of the management, administration and transportation costs of the transportation consortium. m) Schedule [...] to the agreement describes the make up, roles and responsibilities of the CMC. n) Schedule [...] to the agreement sets out the roles and responsibilities of the General Manager. o) Schedule [...] to the agreement provides some specific duties of the General Manager including: [...]. p) Schedule [...] to the agreement describes the mediation and arbitration procedures to resolve any dispute which arises between the Boards. q) [...] is a graphic entitled [...]. 5. ...

The scenarios presented in your request are as follows: Scenario 1 •     1 participant is a large business; the other 2 participants are small/medium-sized businesses. •     The operator is a large business. ... Scenario 2 •     1 participant is a large business; the other 2 participants are small/medium-sized businesses. •     The operator is not a large business. ... Scenario 3 •     All 3 participants are small/medium-sized businesses (none is a large business). •     The operator is a large business. ...