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31 December 2007 GST/HST Ruling 98510- – XXXXX [Frozen] Fruit XXXXX Unedited CRA Tags ETA Sch VI, Part III, 1 Please note that the following document, although correct at the time of issue, may not represent the current position of the Agency. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ...

19 March 2003 GST/HST Ruling 41838- Application of GST to Lease / Sale of Unedited CRA Tags ETA 167(1); ETA 167(1)(a); ETA 167(1.1)(a)(ii); GST/HST Memoranda Series Memorandum 1.4, Goods and Services Tax Rulings Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5 XXXXX XXXXX XXXXX XXXXX Case Number: 41838 XXXXX XXXXX March 19, 2003 Subject: GST/HST APPLICATION RULING Application of GST to lease / sale of XXXXX Dear XXXXX: Thank you for your letter XXXXX (with attachments), concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the transactions described below. ...

The [Corporation] is establishing […], an education program for its licensees to meet their […] education requirements. ... (b) […] Education – the [Corporation] will assess a fee for each hour of instruction which will be equivalent to […] education credit. 6. ... Licensees are required to maintain a number of […] credits specific to their licence […]. e. […] education courses and credits are available to members only. 8. […] The [Corporation] is an ‘other body established by a government’ under Category 1 for the purposes of section 20 of Part VI of Schedule V to the ETA […]. 9. ...

The parties may renew the Agreement […], subject to […] approval for the continued provision of the Services by the City and the Authority. 10. […] of the Agreement outlines the scope of the Service. It provides that the Authority shall commit to the annual operation and maintenance of […] flow gauge stations […] 11. ... According to […] of the Agreement, starting in [yyyy], the annual cost of providing the Service is $ […] and may be subject to annual increases subject to inflationary costs. ...

Additional details are contained in the “Privacy Policy/Terms & Conditions” on the [ACo] Web site: * […] [ACo] provides a way for a customer to communicate their orders to […] [Vendors] […]. * […] once a customer has selected their order […], the customer verifies the order […]. * […] on receipt of the customer’s order, [ACo] will begin processing the order and will send the customer notification by e-mail that payment has been received and that the order is being processed. * […] prices will be as quoted on the Web site. […]. * […]. ... Benefit from advertisements on […]. * Customer Reviews- […]. * […]. * Listings with Partner Websites. * […]. * […]. * Website Integration […]. * Website Creation […]. 13. The […] [options] from which a [Vendor] may select to obtain [ACo] Product & Services […]: * […] [Option #1] $[…] [Joining]Fee, $[…] […] [Equipment] Deposit, […]% [fee] per order (+ applicable taxes) * […] [Option #2] $[…] [Joining] Fee, $[…] […] [Equipment] Deposit, […]% [fee] per order (+ applicable taxes) * […] [Option #3] $[…] [Joining] Fee, $[…] […][Equipment] Deposit, […]% [fee] per order (+ applicable taxes) […] 14. ...

Kit C […] * […] Workbook consists of various exercises on the topic of […]. ... Kit E […] * […] consists of information and various exercises on the topic of […]. ... Kit D- […] * […] contains [#] items, [#] of which are qualifying goods for the Rebate for the following the reasons:- […] is an [#] x [#] printed book which is bound via stapling. ...

STATEMENT OF FACTS * […] * [The Corporation] is responsible for providing comprehensive health services in the […] and […] regions in […][Province 1] servicing [#] communities: […]. * […] is located in the town of […][City 1, Province 1]. It includes the […] located on the […] Indian reserve and the […] located on the […] reserve. * […]. * […]. * [The Corporation] is registered as a charitable organization under the category “Hospitals” by the Charities directorate of the CRA as of [mm/dd/yyyy]. (BN# […]) * [The Corporation] was incorporated as a corporation without share capital in [yyyy]. * Head office of the corporation is located on the […] Indian reserve […]. * By-Law […], Membership states: At all times the Directors described in Section 4.1(1)(a) through Section 4.1(1)(f) shall be members. * By-Law […], Composition of the Board states: The Board of Directors of the [the Corporation] is composed of [#] elected directors and [#] ex officio directors, including: […] * By-Law […], Elected Directors states: […] At the first election of Directors following approval of this By-Law, [#] directors shall be elected for a [#]-year term, [#] Directors shall be elected for a [#]-year term, and [#] Directors shall be elected for a [#]-year term. ...

[The Charity] has entered into […] [Agreement A] with […] [the consultant], located in […], [Participating Province Y]. […] 10. ... " * […] [Details of Agreement A] 11. Pursuant to [Agreement A] […]. 12. ... [The Charity] entered into […] [Agreement B], dated [mm/dd/yyyy], with […] [Participating Province Y] […]. 16. […]. 17. […] [Details relevant to Agreement B] 18. […] [Details relevant to Agreement B] 19. ...

. / 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. ... STATEMENT OF FACTS Based on your letter of [mm/dd/yyyy], we understand […]: […] [information about [Foreign Co A Cdn Branch] and [Foreign Co B Cdn Branch]]. The following diagram provides a summary of the relationship between [Foreign Co A Cdn Branch] and [Foreign Co B Cdn Branch]: [Foreign Holdings Co] / \ / \ / \ [Foreign Co A] [Foreign Co B] | | | | [Foreign Country]__________________________________________________________________ | | | | [Canada] [Foreign Co A [Foreign Co B Cdn Branch] <--------- Cdn Branch] Services RULING REQUESTED You would like to know if […][Foreign Co A] and […][Foreign Co B] are entitled to make the election under section 150 of the ETA with respect to services supplied by [Foreign Co B Cdn Branch] to [Foreign Co A Cdn Branch] (and any other qualifying supply between the parties), so as to deem said supplies to be financial services. ...