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GST/HST Ruling
7 September 2023 GST/HST Ruling 236685a - Purchase of a residential condominium unit
STATEMENT OF FACTS You submitted the following documents for our review: * Statement of Adjustments, […]. * […][Agreement A], signed and dated [mm/dd/yyyy]- only portions of this agreement were provided. * Statements on letterhead of […] indicating lease payments on each of [mm/dd/yyyy], [mm/dd/yyyy] and [mm/dd/yyyy]. * Land Transfer Tax Statement evidencing conveyance of property […]. * […][Lease Agreement]- an incomplete document: it does not identify the parties to the agreement nor is it signed or dated. ... (Footnote 3) * Tenant means [X] and its successors and permitted assigns. * Term means the initial term of the Lease as set out in […] (see below). ... Each statement sets out the following details: * Income Collected – […] $[…] * Expenses Incurred – […]$[…] Although the terms of the lease payments are not set out in the documentation provided, the statements suggest the lease is paid on a monthly basis. 7. ...
GST/HST Ruling
1 June 2021 GST/HST Ruling 192033r2 - Assignment of an agreement of purchase and sale of a condominium unit
. / 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. ... 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. ...
GST/HST Interpretation
31 August 2005 GST/HST Interpretation 63332 - Temporary Importation of Amusement Rides
. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... You intend to temporarily import the following amusement rides to be used at the XXXXX: • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX 2. ... Yours truly, John Sitka Director General Operations and Border Issues Division Excise and GST/HST Rulings Directorate Policy and Legislation Branch 2005/09/26 — RITS 63693 — Tax-paid ...
GST/HST Ruling
28 February 2003 GST/HST Ruling 39945 - Recovery of the Goods and Services Tax on Certain Road Construction Projects
Statement of Facts Our understanding of the facts, the transactions, and the purpose of the transactions is as follows: 1) XXXXX 2) XXXXX 3) XXXXX 4) XXXXX XXXXX · XXXXX · XXXXX · XXXXX- XXXXX- XXXXX · XXXXX · XXXXX · XXXXX · XXXXX · XXXXX · XXXXX 5) XXXXX 6) XXXXX. 7) XXXXX. 8) XXXXX. 9) At XXXXX request, the XXXXX included the construction of XXXXX work in its contract for reconstruction of XXXXX. 10) The XXXXX agreed to do XXXXX work at XXXXX cost and expense. 11) XXXXX · XXXXX- XXXXX- XXXXX · XXXXX · Upon completion of XXXXX work by the XXXXX, XXXXX will, at its cost and expense maintain the work that has been constructed under the Agreement. ...
GST/HST Ruling
15 June 2011 GST/HST Ruling 126726 - Tax Status of Memberships
Section [...] of [Association A] Bylaws states: [...] 14. Section [...] of [Association A] Bylaws states: [...]. ... Section [...] of [Association A] Bylaws states: [...]. 17. Section [...] of [Association A] Bylaws states: [...]. 18. ... Section [...] of [Association A's] Bylaws states: [...]. 21. The following [Associations B] and [...] are [...] ...
Excise Interpretation
15 August 2023 Excise Interpretation 9000189 - FUEL CHARGE INTERPRETATION
L401 & L401-1 – Fuel Charge Exemption Certificate & Schedule : Registered distributor for light fuel oil and gasoline [Province] 2. L402: Fuel Charge Exemption Certificate for Farmers [Province] * Signed on[mm/dd/yyyy], you prepared a written agreement titled […] (Agreement) with [Company B] that was signed by both parties on[mm/dd/yyyy]. ... Yours truly, Angelique St-Pierre Rulings officer Fuel Charge Unit Excise Tax and Fuel Charge Division Excise and Specialty Tax Directorate cc: Enc. ...
GST/HST Ruling
23 June 2000 GST/HST Ruling 8278/HQR0001884 - Application of the GST/HST to Financial Services
The following services are identified in the Schedule of Services: • XXXXX • marketing • XXXXX • accounting • financial analysis • auditing • information processing • personnel, and • investment The Agreement does not provide any details on the services listed in the Schedule. 6. In your letters, you further explain these "services" as follows: • XXXXX • Marketing: This means that XXXXX must actively solicit customers to XXXXX XXXXX (from XXXXX.) • XXXXX. • Accounting: This means that XXXXX must collect and account for XXXXX from the customers. • Financial Analysis: This means that XXXXX must calculate the amount of the XXXXX to be paid by the customer, XXXXX[.] • Auditing: This means that XXXXX must ensure that its intermediary service is in compliance with the agreement. ... This includes verifying that the application has been property completed and that all relevant information has been provided by the customer. • Personnel: This means that XXXXX must provide the necessary people to actively solicit customers. 7. ...
GST/HST Interpretation
4 June 2012 GST/HST Interpretation 133108 - Definition of a "university"
Our understanding of the situation from your [correspondence], [ABC Institution’s] website, the […] Act of […] ([…] [Province X]) and the […] [Province X System] is as follows: [ABC Institution] is a private educational institute […]. [ABC Institution] received permission from the Minister of […] [Province X] Education to offer the Associate of […] degree […]. […] The Associate of […] and Associate of […] Degrees are provincial credentials offered by many institutions in the […][Provincial X System]. ... The Glossary of Terms in the [Province X System] provides the following meanings for the terms “degree”, […]: […] [Terms from the Province X System] According to [ABC Institution’s] website [direct quote] Associate of […] Degree Requirements [ABC Institution] Courses […] The term degree is defined in […] the […] Act of [Province X]. ...
GST/HST Ruling
22 September 2011 GST/HST Ruling 129475 - GST/HST RULING - Application of HST to international student program
Section [...] of the [ABC] Agreement states [...]. 40. Section [...] of the [ABC] Agreement states [...]. 41. ... Section [...] states [...]. 43. Pursuant to section [...], if [Company B] [...]. 44. ... Section [...] states [...]. 50. Sub-paragraph [...] states [...] 51. The MOU sets out the roles and responsibilities of the Corporation as follows: [...] 52. ...
GST/HST Ruling
27 October 2020 GST/HST Ruling 189355 - […][Whether a subcontractor is an agent of a contractor]
It provides […] services. 2. [The contractor] entered into an agreement with [the Municipality] to perform […] work in [the Municipality]. 3. […][the subcontractor] […] provides […] services […]. 4. ... Pursuant to section […] of the Agreement, “[…].” […], [the subcontractor] “…shall secure all permits, fees and licenses necessary […].” ... Pursuant to […] [of the By-law], a […] permit is not transferable. 12. ...