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The four partners are corporations resident in Canada and own the Partnership in the following proportions: Companies % of Ownership XXXXX ("X Co. ...

4 January 2000 GST/HST Interpretation 7137/HQR0000743- GST Rebate Eligibility- Municipal Expense Allowances Unedited CRA Tags ETA 174; ETA 259 Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 14th Floor 320 Queen Street Ottawa, ON K1A 0L5XXXXX XXXXX XXXXX Case: HQR0000743 / 7137File: 11890-5(on)Leg Ref: Section 174 and 259January 4, 2000 Subject: GST/HST INTERPRETATION GST Rebate Eligibility- Municipal Expense Allowances Dear XXXXX I refer to your letter dated April 7, 1997, (with attached reports), concerning eligibility to claim the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) rebate on non-accountable expense allowances paid to council members and volunteer firefighters. ...

In his paper entitled "Hot Topics for Financial Institutions" presented at the 1999 Commodity Tax Symposium, Danny Cisterna of Deloitte & Touche states "(f)or GST/HST purposes and, more specifically, in accordance with the policies set out in Technical Information Bulletin B-032R Registered Pension Plans, an employer engaged in commercial activities that sponsors a pension plan exclusively for its employees is able to claim ITCs in respect of certain administrative expenses relating to the plan. ...

The "place of negotiation" is defined in section 1 of Part I of Schedule IX to the ETA to mean "... the location of the supplier's permanent establishment at which the individual principally involved in negotiating for the supplier the agreement for the supply ordinarily works, or to which that individual ordinarily reports, in the performance of the individual's duties in relation to the activities of the supplier in the course of which the supply is made and, for the purposes of this definition, "negotiating" includes the making or acceptance of an offer. ...

Yours sincerely, Ivan Bastasic Manager Border Issues Unit General Operations & Border Issues Division Excise and GST/HST Rulings Directorate Encl.: Section 1.4 of Chapter 1 of the GST/HST Memoranda Series Customs Memorandum D8-2-25 Value of Imported Goods (GST/HST) Regulations c.c.: Ivan Bastasic Jeff Frobel Legislative References: Sections 212, 214, 215, 252 of the Excise Tax Act NCS Subject Code(s): I1645-3-5 ...

23 March 2001 GST/HST Interpretation 7404- Subcontractors' Progress Payments Unedited CRA Tags ETA 123(1) invoice; ETA 152(1)(c); ETA 168(2); ETA 168(7)(b) Excise & GST/HST Rulings Directorate Place de Ville, Tower A, 15th Floor 320 Queen Street Ottawa, ON K1A 0L5XXXXX XXXXX XXXXXXXXXX Case: 7404XXXXXBusiness Number: XXXXXMarch 23, 2001 Subject: GST/HST INTERPRETATION Subcontractors' Progress Payments Dear Sir: Thank you for your letters of November 27, 1997 and March 16, 2000 (with attachments) concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to progress payments received by subcontractors. ...

A supply of IPP is also considered to be made in a particular province if the "place of negotiation" ("Place of negotiation" is defined as "... the location of the supplier's permanent establishment at which the individual principally involved in negotiating for the supplier the agreement for the supply ordinarily works... ...

Yours truly, Douglas Wood, CGA Rulings Officer General Operations Unit General Operations & Border Issues Division Excise and GST/HST Rulings Directorate c.c.: John Sitka Gunar Ozols Douglas Wood XXXXX Legislative References: section 232 of the ETA section 181.1 of the ETA subsection 123(1) of the ETA- "consideration" B-042 XXXXX XXXXX NCS Subject Code(s): R-11610-1 11610-6 ...

The rebate provision for printed material, pursuant to subsection 259.1(2) of the ETA, is for the GST paid on the purchase of: "... ...

Part VI of Schedule V includes, in section 2, a "supply made by a public institution of any personal property or a service, but not including (...)". ...