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The following information in addition to that provided and contained in our previous interpretations was provided in your letter and our subsequent telephone conversations: •   XXXXX administers musical copyrights on behalf of their clients, some are resident in Canada and others are not. •   XXXXX supplies rights to music copyrights administered and/or owned by them to sub-publishers (SP) located in foreign jurisdictions in order to facilitate the collection of royalties generated outside Canada. •   The supply of the copyrights include performing rights and reproduction rights. •   The SP's collect public performance royalties (for radio and TV play) and mechanical royalties (for CD sales) generated for uses of the musical property earned in these foreign jurisdictions. ... Frobel Border Issues Unit General Operations and Border Issues Division GST/HST Rulings and Interpretations Directorate c.c.: Jeffrey Frobel,   General Operations & Border Issues Division,   Borders Issues Unit Ivan Bastasic,   General Operations & Border Issues Division,   Borders Issues Unit Raymond Labelle,   General Operations & Border Issues Division   Services and Intangibles Unit XXXXX XXXXX Legislative References: Subsections 142(1), 142(2), 177(2) of the Act Section 10 of Part V of Schedule VI to the Act NCS Subject Code(s): 11640-2, 11680-1 ...

The Park is located at [...] in [...] [Community 1], in the municipality of [...], [...] ... You own your unit, a [...] park model, which measures [...]' x [...]'. ... The site is fully landscaped and has a [...]' x [...]' concrete driveway. ...

The Park is located at [...] in [...], in the municipality of [...], [...] ... The unit measures [...] x [...] feet. You had an addition measuring [...]' x [...]', also manufactured by [...], attached to the unit, providing a total living area of about [...] square feet. 8. ... You paid rent monthly, and you were temporarily away from the trailer park [...] during the winter, generally during [...]. 10. ...

You provided a copy of the following documentation: * Term Sheet dated [mm/dd/yyyy], between […][ACo] and […][BCo]; * Assignment Agreement dated [mm/dd/yyyy], between [ACo], […][CCo], and [BCo].; and * Acknowledgement and Agreement dated [mm/dd/yyyy], 2013, addressed to [CCo] and signed by […] on behalf of [BCo]. ... The Term Sheet set out terms and conditions that would be subject to the full scrutiny of a due diligence review that would include, but not necessarily be restricted to, considerations contemplated therein, as follows: * Borrower: [BCo] * Lender: [ACo] or any company [ACo] chooses to use * Loan Facility: a demand term loan in the amount of $[…] * Rate of Interest: […] plus […]% per annum payable monthly in arrears. * Commitment Fee: $[…] plus HST is payable on the execution by [BCo] of the Lender’s Commitment Letter (which we understand to be the Term Sheet itself). * Closing Fee: [BCo] agrees to pay a fee equal to [#]% of the maximum of the Loan Facility, which is earned at the time the Lender first advances the Loan Facility with payments being postponed until the earlier of the maturity date of the Loan Facility or payout of the Loan Facility. * Term: […] months, on demand. * Interest Rate Adjustment Date: [BCo] shall pay interest on the entire loan facility amounts monthly, in arrears, on the 30th day of each month. ... On [mm/dd/yyyy], [ACo], [CCo], and [BCo] entered into an Assignment Agreement (Assignment Agreement) which contained the following provisions: * Pursuant to the Term Sheet, [ACo] agrees to make certain loans and advances to [BCo], subject to the terms and conditions of the Term Sheet (the “Credit Facilities”); * Pursuant to terms of the Term Sheet, [ACo] has the discretion as to the entity that will enter into the loan arrangements with [BCo] and fund the advances made to [BCo] pursuant to the Term Sheet; * [ACo] has designated [CCo] as the Lender under the Term Sheet; * For consideration of $[…] paid by [CCo] to [ACo], [ACo] assigns to [CCo] all of its right, title and interest in the Term Sheet and the Credit Facilities. * [ACo] represents that the Term Sheet is in full force and effect and unamended and [ACo] has not knowingly discharged [BCo] from the Term Sheet or assigned any rights or obligations under the Term Sheet; * [CCo] accepts the assignment of [ACo]’s rights and obligations in the Term Sheet and indemnifies [ACo] from any claims by [BCo] arising in connection with the Term Sheet or the performance of the Lender’s obligations under the Term Sheet; * [BCo] acknowledges that it has taken notice of the assignment and expressly consents to it. * The Assignment Agreement sets forth the entire agreement and understanding among the parties with respect to the subject matter and supersedes any prior agreements or understandings, whether oral or in writing. ...

We understand the following: •   XXXXX (the Company) is a non-resident tour operator that is not registered for GST/HST purposes. •   The Company has an office (i.e., a permanent establishment) in XXXXX from which it conducts its travel business. •   The Company sells tour packages to non-residents XXXXX at an all-inclusive price for a skiing vacation in Canada. •   The Company's tour packages may include: –   accommodation; –   ski lift passes; –   ski lessons; –   ski guides; –   transfers (i.e., Airport or mountain); and –   international and domestic air travel. •   The Company has XXXXX to pay its Canadian suppliers. ... Some examples of services include: •   guide (e.g., ski guide) or interpreter services; •   transportation services (i.e., air travel); •   sightseeing excursions; and •   ski lessons. ... The following do not qualify as services as they are property: •   short-term and camping accommodation; •   meals; •   a right to enter or attend an event, such as tickets to a show or a hockey game; •   car rentals; •   ski rentals; •   ski lift passes; and •   park passes. ...

CANCO derives its revenues from supplying the following services: •   Setup fee- A one-time fee charged to set up an account. •   Monthly account fee- A monthly service fee charged to maintain the status of the account. This service includes: real-time transaction processing, WebPOS terminal, batch processing, and recurring billing services. •   Merchant accounts discount- A charge based on a percentage of credit card dollar volume processed. •   Shopping Cart fees- A monthly fee charged for using CANCO's shopping cart services. •   Various fees charged per transaction or instance (for some customers some of the services listed below may be included in the monthly account fee): •   Transaction processing. •   Pre-authorized transactions. •   Electronic funds transfer between financial institutions. •   Transaction and sales analysis. •   Fraud screening. •   Address correction. •   Inventory management. •   Demographics information. ...

You also provided the following documents: •   A copy of the XXXXX Affinity XXXXX Program Agreement between the Association and Party A. •   A copy of the Business Agreement between the Association and Party B. •   A copy of the Agreement between the Association and Party C. •   A copy of the Agreement between the Association, Party D and Party E. •   A third party authorization that authorizes XXXXX to represent the Association. ... Party C •   Party C wishes to offer XXXXX to the Association members, staff, Party F and their spouses (collectively referred to as the Members). •   In the agreement entered into with Party C, the Association agrees to •   Encourage the participation of its Members in the XXXXX; •   Provide to Party C, at their request, access to updated lists of the XXXXX of the Association, including their name, address and telephone numbers for solicitation and promotional purpose; •   Authorize Party C to use the names, trademarks, crests and logos of the Association on all related XXXXX documentation; •   Offer exclusively to Party C any XXXXX advertisement in the Association's official publications; and •   Not sponsor any other XXXXX during the term of the agreement. •   In the agreement Party C agrees to •   Ensure that the XXXXX will be administered in accordance with the present agreement; •   Accept all reasonable requests for XXXXX under the XXXXX; •   Give the Association the information contained in XXXXX, that being statistical information on the number of: •   XXXXX; •   XXXXX; •   XXXXX; •   XXXXX; and •   XXXXX. •   Promote the XXXXX using various promotional methods; •   Assume all costs associated with the XXXXX- from package design, promotional material, mailing, postage, insurance policies, etc.; and •   Indemnify and save the Association harmless. •   In consideration for the exclusive right given to Party C to promote the XXXXX and subject to access of updated lists of the XXXXX of the Association, Party C will provide the Association with the following financial consideration during the term of this agreement. ... As previously mentioned, the Program refers to XXXXX to the Members; •   Compensate the Association on the XXXXX of each XXXXX to Members; •   Along with Party D, collaborate with the Association to offer the Members the Program; •   Pay the Association XXXXX per XXXXX for any Member; •   Send out two direct mail pieces per year to all mailable Association XXXXX. ...

STATEMENT OF FACTS We understand the following from […] [the] fax, additional documents including a sample […][agreement] (footnote 1) (the Agreement), the company’s website […], and [various] telephone conversations held between […] and […][CRA officials]: 1. […] ([…] [ACo]), […], is a non-resident corporation that is registered for the GST/HST under Subdivision d of Division V. 2. ... According to […] the Agreement: […] 14. [ACo] retains exclusive ownership of all applicable copyrights, trade secrets, patents, and other intellectual property rights in the Software according to […] the Agreement, […] […] 15. ... The [Representatives] shall pay any […] taxes, fees or duties […], including but not limited to, taxes due and owing on amounts due or collected from end-users to the [Representative]. […] 31. ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... The Company's web site provides information on XXXXX, the key ingredient in all of its products: XXXXX: •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX Ruling Requested You would like to know the tax status of the products. ... Yours truly, Jacqueline Russell Goods Unit General Operations and Border Issues Division Excise and GST/HST Rulings Directorate 2006/06/26 — RITS 57757 — Interpretation of Section 174 of the Excise Tax Act ...

1 February 1996 GST/HST Interpretation 11705-4- The Requirements for the Disclosure of Tax Under the Excise Tax Act (the Act) Unedited CRA Tags ETA 223(1)                                                                         Facsimile #: (613) 990-1233                                                                         File no.: 11705-4(FP)                                                                         S. 223(1)                                                                         XXXXX Dear XXXXX This is in response to your meeting with this Department on February 6, 1992 and your phone conversation with François Paris of my staff on February 8, 1996 regarding the requirements for the disclosure of tax under the Excise Tax Act (the Act). ... Jones Director General Applications Division GST Rulings and Interpretations Policy and Legislation Branch GAD #: 2718 (GEN) c.c.: All regions XXXXX M. ...