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. / 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. ... Issue 1 – Third Party pension expenses incurred by a participating employer of a pension plan SCENARIO: * […] ([…] [The Corporation]) is a registrant and a “participating employer” as defined in subsection 172.1(1). * The [Corporation] Pension Plan (the “Plan”) is a registered pension plan that governs a person that is a trust, and the trust is a “pension entity” of the Plan as defined in subsection 261.01(1). The pension entity is resident in Canada and a selected listed financial institution. * [The Corporation] entered into contracts with non-resident third parties (e.g., […] ([…] [A Co]) and […] ([…] [B Co])) to supply investment management services relating to “pension activities” (Footnote 1) of the Plan. ...

DOCUMENTS PROVIDED The summary of background facts in the next section is based on the following documents and correspondence: […][listing of documents submitted] SUMMARY OF BACKGROUND FACTS Key Services Provided and Ultimate Transaction * A summary of the key features in the foregoing documents, that would be relevant to the characterization of the services provided to the Company by the Service Provider, is set out in the attached […]. * The documents submitted […] relate to the services that the Service Provider agreed to provide to the Company in connection with a potential disposition of the Company's financial services operations, either by way of a sale of receivables, or a sale of […] shares, as well as entering into a […] program with a purchaser […]. * According to the Purchase Agreement […], the ultimate transaction took the form of a sale of assets of the Business, consisting of the […] Activity, the […] Products Activity and the […] Program (the Transaction; capitalized terms have the meaning set out in the Purchase Agreement; "transaction" in lower case refers to potential transactions in general, with respect to which the Service Provider was engaged). * While there are many descriptions of the Service Provider's role in the various documents, key elements of the descriptions may be summarized as follows: 1. Acting as a financial advisor, advice re evaluation of strategic alternatives including structure of the Transaction […] as demonstrated by: […]. 2. Assistance in searching for a purchaser […] and organizing the bidding process, including ongoing liaison and co-ordinating visits, as demonstrated by the following: […]. 3. ...

The purpose of the Corporation is […] 3. The members of the Corporation are: […][Member #1], […]. 4. ... [Member #1] registered for GST/HST purposes on [mm/dd/yyyy]. 14. […]. 15. ... Yours truly, Desneiges Arbour Charities and Non-profit Organizations Unit Public Service Bodies and Governments Division Excise and GST/HST Rulings Directorate FOOTNOTES 1 […]. 2 […]. 3 […].     ...

1 March 1996 GST/HST Interpretation 11895-1[11]- Clarification of Departmental Interpretation of Subsection 141(1) of the Excise Tax Act (the Act) as it Applies to Operations of Commissions Unedited CRA Tags ETA 141(1); ETA 169(1)                                                                         File #: 11895-1(on)                                                                         c.n. 2431(GEN)                                                                         Sch. V/VI/28 ss. 141(1) & 169(1) XXXXX March 1996 Dear XXXXX I refer to your letter of August 30, 1995, seeking clarification of our interpretation of subsection 141(1) of the Excise Tax Act (the Act) as it applies to operations of XXXXX commissions. ...

The [...] Act was assented to on [mm/dd/yyyy]. 2. According to section [...] of the [...] ... Under section [...] of the [...] Act [...]. [direct quote from legislation] 5. Under section [...] of the [...] Act [...]. [direct quote from legislation] 6. ...

STATEMENT OF FACTS We understand the following information pertaining to your request: 1. […], […] and […] (the requestors) have mushroom growing operations in the listed province of […]. 2. ... The natural gas provider did not provide relief based on the conclusion that […] and […] do not operate an eligible greenhouse. ... As mushroom is a fungus generally requiring dark conditions for growth, a person in the business of growing mushrooms would not be considered a greenhouse operator. […], […] and […] are not greenhouse operators nor do they operate eligible greenhouses. ...

The Municipality leases the second storey of a local elementary school from XXXXX, and sub-leases it to the following organizations: •   XXXXX; •   XXXXX; •   XXXXX; and •   XXXXX. 3. The Municipality also leases spaces in buildings it owns to separate entities that operate the following: •   a community health clinic; •   a health unit; •   a mental health unit; and •   a canteen. 4. ... Boivin Manager Real Property Unit Financial Institutions and Real Property Division Excise and GST/HST Rulings Directorate 2007/07/09 — RITS 80137 — Federal Printed Book Rebate ...

The classes of members are as follows: •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX The Association has not collected GST/HST on its memberships. ... XXXXX $XXXXX •   One complementary pass to the Symposium •   Signage •   Recognition of the sponsor's logo in printed material •   Opportunity to display the sponsor's promotional material XXXXX $XXXXX •   Recognition in binder materials, signage and in printed material for the sponsorship of any of the following: •   A coffee break •   Morning speaker •   A break-out panel sponsor •   Debate session sponsor •   Afternoon speaker. ... The XXXXX will provide: •   Program administration; •   Marketing; •   Desktop design of conference brochure; •   Sales and registration; •   Conference coordination; and •   Post event management. ...

You […] asked […] whether […] supplies of certain yogurt based products are zero-rated or excluded from zero--rating under one of the paragraphs of section 1 of Part III of Schedule VI to the Excise Tax Act (ETA). ... That is, the products are not homogenous.[…], the Company stated that three of its products […] contain […]%,[…]% and […]% yogurt by weight. ... We note that […] products […] contain greater than 50% yogurt by weight. […] these products are characterized as yogurt and are zero--rated for GST/HST purposes provided that they are not sold from an establishment within the store which would result in supplies of such products being taxable under paragraph 1(q). ...

[Game Card 9] give[s] customers a membership for a period of [...] for the price of $[...] and $[...] respectively for online activities on the [...] website. [...]. ... The [...] subscription is sold for $[...]. 11. [...] [Games Points Card 11] for a retail price the customers purchase or [...] points which will allow them to do online shopping for games for their [...] system. ... The [...] points card is sold for $[...]. You also included in your submission a [...] card. ...