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STATEMENT OF FACTS Based on the information you provided, our understanding of the facts is as follows: Parties involved: * […] (Vendor) – sets up ATM bank machines (i.e., sells equipment & related software licences), * […]([…][X]) – assignor and subsequently lessee, * […] (Lessor), a non-depository short term credit institution that provides primary equipment financing through leases – assignee and subsequent lessor All parties are registered for GST. Facts: * [X] enters into an “Acquisition Agreement” to acquire equipment & software licenses from the Vendor. * [X]’s acquisition of the equipment does not include the purchase of any software which is licensed to [X] by the Vendor. ... It is not clear how this particular taxable supply was accounted for, since the full Equipment Lease Agreement [#] was not submitted […]. […] […] [ABC] has referred to section 165 of the ETA to say that “every recipient of a taxable supply made in Canada” shall pay GST/HST based on the “value of the consideration for the supply”. ...

In sum, [to be considered] an “in vitro diagnostic test” […][for GST/HST purposes]: * The test is for use in the diagnosis of a disease in humans and; * The test contains at least one of the four substances listed above. ... The Oxford Concise Medical Dictionary defines “diagnosis” as “the process of determining the nature of a disorder by considering the patient’s signs and symptoms, medical background, and – when necessary – results of laboratory tests and X-ray examinations”. ... Yours truly, Kassandra Leonard Health Care Sectors Unit Public Service Bodies and Governments Division Excise and GST/HST Rulings Directorate FOOTNOTES 1 [...] 2 [...] 3 [...] 4 […] 5 […] ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... XXXXX: •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX In a telephone conversation and in a subsequent e-mail, you mentioned that XXXXX also provides a XXXXX. ... Yours truly, Gabrielle Nadeau Goods Unit General Operations and Border Issues Division Excise and GST/HST Rulings Directorate 2005/12/05 — RITS 62908 — Eligibility for the Code 8 Rebate of Travel Allowances Given to Employees as an Inducement to Gain or Maintain Their Employment ...

The charge to the individual is $[…]. * Complex medication review where the individual takes [#] to [#] medications and has [#] to [#] medical conditions. The charge to the individual is $[…]. * Follow-up appointment after completion of the medication review. ... The charge to the individual is $[…]. * Follow-up appointments in a package of [#] appointments over a […] period. ...

EXEMPT $         0 G.S.T. (R.......) $  2,415 Total $36,915 Less Deposit $- ___ Balance Owing on Delivery $36,915 A typical worksheet would be as follows: Lessee Deemed sale of used vehicle $  10,500 GST collected $   735 [i] (1) Deemed Payment re new vehicle $- 10,500 GST collected $- 735 [ii] (1) Net Cash Received by Lessee $           0 Dealer Sale of New Vehicle Base Cost $  45,000 Licence $           0 Air Conditioning $ 0 $  45,000 GST Collected $3,150 [iii] (1) Deemed Purchase of Used Vehicle $-10,500 GST Paid  -     735 [iv] (1) Net Cash received by dealer $ 36,915 Lessor Deemed purchase of used vehicle $-10,500 GST paid $- 735 [v] (1) Deemed payment by lessee $  10,500 GST collected $  735 [vi] (1) Net Cash to Lessee $           0 Purchase of New Vehicle Base Cost $   45,000 Licence $            0 Air Conditioning $ 0 $   45,000 GST Paid $ 3,150 [vii] (1) Deemed sale of used vehicle $- 10,500 GST collected $- 735 [viii] (1) Net Cash to Dealer $   36,915 In the above example, it is assumed that the lessee owns a vehicle with a fair market value of $10,500 and wishes to lease a new vehicle worth $45,000. ...

15 March 1996 GST/HST Ruling 11640-4[3]- Application of the GST to the Supply of Coloured Toner Unedited CRA Tags ETA Sch VI, Part V, 1                                                                         Telephone #: (613) 954-8585                                                                         Fax #: (613) 990-1233                                                                         File #: 11640-4(glr)                                                                         Sch. ... Nanner        GAD #: 2693(GEN) G. Ryhorchuk XXXXX ...

Shares") at a price of $[...] per share (max. [#] shares / $[...]). ... Management Fee and a [...] Service Fee [...]. The Service Fee is equal to [...]% [...] of the [...] Shares (subject to certain adjustments) held [...] by the Clients [...] [...] the Agreement and the Prospectus both state that the Investment Manager is required to pay to the Dealers a service fee [...] based on the number of [...] ...

For example, the Law Firm’s statements of account itemized the following services: * Drafting and issuing Statement of Claim; * Reviewing all pleadings; * Attendance at Examinations for Discovery; * All settlement negotiations; * Reviewing all accident benefits documentation; and * Settling of claim for civil damages. 4. The statement of account for [mm/dd/yyyy], indicates that the Law Firm received $[…] in trust as settlement and that the Law Firm’s fees of $[…], HST of $[…], and two other disbursements ($[…] paid to […][A] and $[…] paid to […][B]) were deducted from that amount and the remainder of $[…] was paid to you. 5. ... It shows that the Law Firm’s fees of $[…], HST of $[…], disbursements of $[…], and HST of $[…] were deducted from that amount and the remainder of $[…] was paid to you. 6. ...

The supplies made by the Corporation to owners and lessees of the units include the following: •   Electricity •   Repairs and maintenance •   Groundskeeping •   Garbage removal •   Insurance •   Management fees •   Water and sewer •   Snow removal and street cleaning[.] 6. ...

[The] [...] (Franchisor) is one such franchise banner. The Franchisor has [...] for use in [...] a mortgage brokerage business [...]. ... Franchise only at a specific location and [...]. 5. Under [...] the Franchise Agreement, the Franchisee shall pay to the Franchisor an [...] franchise fee [...] in the amount of $[...]. ... Under [...] the Franchise Agreement, the Franchisee shall pay the Franchisor a [...] franchise fee equal to [...]% of [...]. ...