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CRA stated: [T]he Cooperative was a transit authority … as it was a non-profit organization that received funding from the Province and the Municipality to support the supply of public passenger transportation services, and all or substantially all of the its supplies were supplies of public passenger transportation services provided within the Municipality and its environs. ...

. – “the supply of the rehabilitation program would be subject to the GST/HST.” ...

. … [I]f TPP is supplied on a delivered basis, it would be inappropriate to artificially split the supply into two separate components, for the reasons indicated in P-077R2. ...

Consequently … no agency relationship exists between the vendor and the purchaser, and therefore, the prepayment of property taxes by the vendor cannot be treated as a non-taxable reimbursement of taxes paid as agent for the purchaser. ...

. … Current audit procedures require the auditor to verify the validity of the NRRPR and, if the NRRPR is valid, to send the rebate claim to be keyed into our system and processed with an effective date that is the same as the due date of the registrant’s return. ...

. … [M]onies that are provided to an organization under agreements between the organization and a government or municipality for the provision of training to a particular group of students, such as recipients of income or employment assistance, do not meet this requirement. ...

. … Responsibility of resident supplier to obtain certificate or other residency evidence Responsibility of registrant suppliers 16. ...

. … Intangible personal property 58. Intangible personal property includes contractual rights, options, shares in the common stock of a corporation, the right to recover a debt, intellectual property (patents, trade-marks, trade-names), and rights in relation to goods that are not in possession and other rights which may be enforced by the courts, but does not include money. ...

. … [T]he CRA will continue to contemplate the application of the GAAR to transactions undertaken primarily to secure a tax benefit afforded by a tax treaty. ...

GST29 Educational Services- Election and Revocation of the Election to Make Certain Supplies Taxable-- summary under Section 6 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule V- Part III- Section 6 Description of election under s. 6 (Type 1) Type 1 Election (section 6 of Part III of Schedule V to the Excise Tax Act) – Fill out Part 2 to elect to have GST/HST apply to your supplies of instructing individuals in, providing certificates for, or administering examinations for, courses that lead to, maintain, or upgrade a professional or trade accreditation or designation recognized by a regulatory body. ...