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15 November 1996 GST/HST Interpretation 11690-8[1]- Registration of Non-Resident Corporation Unedited CRA Tags ETA 123(1) permanent establishment; ETA 132(2)                                                                         Telephone #: (613) 954-8585 Fax #: (613) 990-1233 XXXXX                                                                                 File #: 11690-8(glr) XXXXX                                                                                 HQR0000122 XXXXX                                                                                 ss. 123(1), 132(2) XXXXX ATTENTION: XXXXX November 15, 1996 I refer to XXXXX E-mail message of August 9, 1996, concerning the eligibility of a XXXXX company, specializing in hospital software, to register for Goods and Services Tax (GST) purposes. XXXXX provided the following facts in his message: •   AXXXXX company specializing in hospital m.i.s.-software applications has an employee in Canada solely for the purpose of installing XXXXX-supplied software. •   The service of installing the software is included in the price of the software. •   The only additional billings for the employee's services will be for training or emergency support services (the likelihood of either is small to insignificant as "user-support" services are supplied from XXXXX either on-line or by telephone). •   The Canada-based employee works from an office in his home. ...

Paragraph […] provided that the buyers agreed to pay a brokerage fee of $[…] (Fee) plus applicable GST and any other applicable tax. ... On [mm/dd/yyyy], the lawyers sent a letter to [the client] and the broker with an enclosed cheque for $[…] which sum represents the balance of the settlement monies of $[…], less the sum of $[…] for legal fees. ... On [mm/dd/yyyy], the broker issued a cheque to the company for the sum of $[…] ($[…] plus [$][…] GST less a deal fee of $[…].) ...

These additional sponsorship features include: a) Joint Venture Team (Cash sponsorship of XXXXX or more): •   full page advertisement in the final program; •   opportunity to XXXXX •   opportunity to make a brief presentation to conference delegates affirming sponsor's support of the XXXXX industry; •   five complimentary conference registrations, with an additional complimentary registration for each additional XXXXX •   opportunity to add XXXXX to the sponsor's Internet home page; •   opportunity to incorporate XXXXX into the sponsor's print materials; •   recognition in all media releases; •   all benefits of the XXXXX level (see below). b) XXXXX (Cash sponsorship of XXXXX •   complimentary hospitality suite (one night); •   complimentary exhibit booth XXXXX value); •   four complimentary registrations XXXXX value); •   early and final registration lists of delegates and exhibitors. c) XXXXX (Cash sponsorship of XXXXX •   complimentary hospitality suite XXXXX •   complimentary exhibit booth XXXXX value); •   three complimentary registrations XXXXX value); •   early and final registration list of delegates and exhibitors. d) XXXXX (Cash sponsorship of XXXXX •   complimentary exhibit booth XXXXX value); •   two complimentary registrations XXXXX value). e) XXXXX (Cash sponsorship of XXXXX •   one complimentary registration XXXXX value). 5. ... Furthermore, it is our ruling that the sponsorship payments are in respect of promotional supplies to which section 135 (see Explanation below) of the Excise Tax Act ("ETA") applies, and in respect of the following taxable supplies: •   conference registrations; •   exhibit booth; and •   hospitality suite. The following promotional supplies made by XXXXX in exchange for the sponsorships fall within the parameters of section 135 of the ETA: •   recognition of sponsor on conference signage; •   recognition of sponsor in promotional brochures; •   sponsor's profile included in the final conference program; •   sponsor's receipt of a full-page advertisement in the conference program; •   recognition of sponsor in conference media releases; •   sponsor's right to include information and promotional items in registration kits; •   sponsor right to use of XXXXX logo on sponsor's Internet home page; •   sponsor right to use of XXXXX logo in sponsor's print materials; •   sponsor's right to express registration and conference check-in (incidental); •   early and final registration lists of delegates and exhibitors (incidental), •   sponsor's right to chair sessions; and •   sponsor's right to make a presentation to delegates.   ...

Investors had made their investments under the assumption that ABC XXXXX would be in the leasing business and the company in anticipation of entering into the leasing business took the below actions: •   selected premises with a store front and lot necessary for a leasing operation; •   obtained contingent lessor's insurance in anticipation of leasing; •   became a member of various organizations and associations involved in leasing; and •   became a licensed as a dealer, which is required as a lessor, but not as a finance company. Initial expenses to start up the business consisted of the following examples: •   computer equipment; •   rental of space, •   renovation costs; •   utilities; •   legal and accounting; and, •   meals and entertainment. ...

Statement of Facts You have provided with your letter copies of the agreement of purchase and sale dated April [...], 2010, Addendum Schedule [...] and Addendum Schedule [...] both dated April [...], 2010, a counter offer dated April [...], 2010, and a Notice of Removal of Schedule [...] dated May [...], 2010. ... Addendum [...] states that the purchase price is to read $[...] including applicable tax, and the closing date is to read on or before August [...], 2010. 5. ... Addendum Schedule [...] states the buyers and the seller agree that the buyers are to provide a certified cheque in the amount of $[...]. ...

X]. […] [Executor A’s] GST/HST account […] status […][is] currently “active”, […][Executor A’s] filing status is “non-filing”, and [Executor A’s] reporting period [is] “non-reporting”. […] [Executor A’s] business activity […][is reported] to be […]. 2. ... The Estate paid an Attorneyship fee of $[…] to [Executor A] […][around that same date and] remitted an amount of $[…] as HST directly to the Receiver General, by way of a bank draft ([…]). 5. ... The CRA deposited both of the above mentioned bank drafts on [mm/dd/yyyy], and the payments were posted to an account number […]. 7. […], the CRA received a completed General Application for Rebate of GST/HST (GST189) […] requesting a rebate of tax paid in error for a total of $[…] in respect of the […][amounts] remitted by the Estate as tax in respect of [Executor A's] Attorneyship fees [and] […] Executorship fees. 8. […]. 9. […]. 10. […]. 11. […][Subsequently], the Estate requested that the amount of the rebate request be increased to include also the $[…] remitted directly by the Estate as HST in respect of the Executorship fees paid to [Executor B], [thereby] increasing the rebate requested to $[…]. 12. ...

Travel Agency's books and records: Invoice to customer Air fare $500.00 HST     75.00 Total Air fare   575.00 Hotel Accommodation   200.00 GST     14.00 Total Hotel Accommodation   214.00 Total Payable by customer $789.00 Invoice to air carrier Commission earned $50.00 HST     7.50 Total Payable by air carrier $57.50 Invoice to hotel Commission earned $30.00 HST     4.50 Total Payable by hotel $34.50 Travel agency's GST/HST return: GST/HST collectible $12.00 Input tax credits (GST/HST paid out)    0.00 Total GST/HST remittance $12.00 Travel agency's statement of account: Total collected from customer on behalf of air carrier and hotel   789.00 Less commissions earned and applicable HST     92.00 Amount to be forwarded $697.00 Air Carrier's books and records: Revenues: Air fare $500.00 HST     75.00 Total Air fare $575.00 Expenses: Travel agency's commission on air fare $50.00 HST     7.50 Total Payable to travel agency $57.50 Air carrier's GST/HST return: GST/HST collectible $75.00 Input tax credits (GST/HST paid out)     7.50 Total GST/HST remittance $67.50 Hotel's books and records: Revenues: Hotel accommodation $200.00 GST     14.00 Total Payable by travel agency $214.00 Expenses: Travel agency's commission on hotel accommodation $30.00 HST     4.50 Total Payable to travel agency $34.50 Hotel's GST/HST return: GST/HST collectible $14.00 Input tax credits (GST/HST paid out)     4.50 Total GST/HST remittance $  9.50 The latter portion of each response will provide general statements on each scenario. ... Travel Agency's books and records: Invoice to customer Air fare $500.00 GST     35.00 Total Air fare   535.00 Hotel Accommodation   200.00 HST     30.00 Total Hotel Accommodation   230.00 Total Payable by customer $765.00 Invoice to air carrier Commission earned $50.00 GST     3.50 Total Payable by air carrier $53.50 Invoice to hotel Commission earned $30.00 GST     2.10 Total Payable by hotel $32.10 Travel agency's GST/HST return: GST/HST collectible $5.60 Input tax credits (GST/HST paid out)   0.00 Total GST/HST remittance $5.60 Travel agency's statement of account: Total collected from customer on behalf of air carrier and hotel $765.00 Less commissions earned and applicable GST     85.60 Amount to be forwarded $679.40 Air Carrier's books and records: Revenues: Air fare $500.00 GST     35.00 Total Air fare $535.00 Expenses: Travel agency's commission on air fare $50.00 GST     3.50 Total Payable to travel agency $53.50 Air carrier's GST/HST return: GST/HST collectible $35.00 Input tax credits (GST/HST paid out)     3.50 Total GST/HST remittance $31.50 Hotel's books and records: Revenues: Hotel accommodation $200.00 HST     30.00 Total Payable by travel agency $230.00 Expenses: Travel agency's commission on hotel accommodation $30.00 GST     2.10 Total Payable to travel agency $32.10 Hotel's GST/HST return: GST/HST collectible $30.00 Input tax credits (GST/HST paid out)     2.10 Total GST/HST remittance $ 27.90 General comments on Scenario 2: The customer is required to pay the HST and the GST. ... Portion of the price that is attributable to the air fare (supply made in Nova Scotia) $500.00 HST     75.00 Sub-total $575.00 Portion of the price that is attributable to the hotel accommodation, car rental and meals (supplies made in British Columbia): $   500.00 GST        35.00 Sub-total $   535.00 Total payable by customer $1,110.00 Invoice to tour operator Commission earned $100.00 HST     15.00 Total Payable by tour operator $115.00 Travel agency's GST/HST return: GST/HST collectible $15.00 Input tax credits (GST/HST paid out)     0.00 Total GST/HST remittance $15.00 Travel agency's statement of account: Total collected from customer on behalf of tour operator $1,110.00 Less commission earned and applicable HST      115.00 Amount to be forwarded to tour operator $   995.00 Tour Operator's books and records: Revenues: Tour package sold for $1,000.00 Portion of tour package where HST applies: ($1,000 x 50%) $   500.00 HST        75.00 Sub-total $   575.00 Portion of tour package where GST applies: ($1,000 x 50%) $   500.00 GST        35.00 Sub-total $   535.00 Total $1,110.00 Expenses: Travel agency's commission on tour package $100.00 HST  15.00 Total Payable to travel agency $115.00 Tour operator's GST/HST return: GST/HST collectible $110.00 Input tax credits (GST/HST paid out)     15.00 Total GST/HST remittance $  95.00 General comments on Scenario 5: The customer is required to pay the HST and the GST. ...

Facts Provided: •   Value of the new vehicle: $20,000 •   Value of the trade-in vehicle: $20,000 •   Lien on the trade-in vehicle: $18,000 •   Lease payments on the new vehicle: $300/mth Department's assumptions: •   The customer is a non-registrant and the dealer is a registrant; •   Lease period on the new vehicle: 48 months •   Residual value on the leased new vehicle: $8,000 •   Money factor (interest rate): 0.0% Response requested: (i) GST charged on the monthly lease payments- 7% x ($20,000- $20,000- $8,000) / 48 months: Nil Example #3: Accommodation sale. Facts provided: •   A non-registrant vendor wishes to sell their vehicle to a non-registrant purchaser; •   The vendor sells the vehicle to a dealer as a trade-in and purchases a new vehicle from that dealer; •   The dealer sells the trade-in vehicle to the purchaser; •   Sale price of the new vehicle: $20,000 •   Value of the trade-in vehicle: $  5,000 •   Sale price of the trade-in vehicle to the purchaser: $  5,000 Department's assumption: •   The dealer is registered for the GST. ... Facts provided: •   Purchase price of the new vehicle: $20,000 •   Residual value of the old leased vehicle: $  5,000 •   Value of the old leased vehicle: $  7,000 Department's assumptions: •   The non-registrant exercises the buy-out option on the old leased vehicle; •   The registered dealership accepts a trade-in of $7,000 for the old leased vehicle. ...

Response •   The provision of the engineering service is not within the ambit of subsection 162(1) and is therefor a taxable supply; •   The time of supply is deemed to be at the time the contract is entered into; •   Tax is due at the earlier of the day the consideration is paid or becomes due; •   The provision of subsection 168(2) is operative such that tax becomes payable on each payment. ... Research •   Letter of XXXXX •   P-128 •   P-110 •   Explanatory notes 4. Carlson & Associates Advertising Ltd v The Queen ...

You describe the Product as organic bread […] 3. The Product is further described as a dinner-sized bread weighing […] grams and available in salty and sweet varieties. 4. ... In baking the Product, the dough is […] 6. There are 3 varieties of the Product: 1. […] – […][describes ingredients of variety 1]; 2. […] – […][describes ingredients of variety 2]; 3. […] – […][describes ingredients of variety 3]. 7. ... For example: • if they are sold from a heated cabinet, they are not zero-rated; • if the establishment has a separate take-out counter, any hot foods sold from this counter are not zero-rated; or • if the food and beverages are purchased and heated at the point of purchase, they are not zero-rated. ...