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We reviewed the following documents in connection with your request: * […][Agreement 1] dated [mm/dd/yyyy] […] between [the Investor] and […](Corporation 1); and * […][Agreement 2] dated [mm/dd/yyyy] […] between [the Investor] and a non-resident corporation (Corporation 2). ... [Agreement 1] includes the following key provisions: Recital “The Purchaser [[…][the Investor]] wishes to acquire from the Corporation, […], a gross sales royalty […] on the terms and conditions contained herein.” […] Gross Sales Royalty “As consideration for the payment by the Purchaser of the Royalty Acquisition Amount, and subject to the terms hereof, the Corporation […] agrees to pay to the Purchaser a royalty payment ([…] a “Royalty Payment”) equal to […]% of monthly IP Revenue earned by the Corporation during each calendar month, […].” […] Buyout Option “[…] the Corporation shall have the right to purchase and extinguish, fully and not in part, all amounts owing to the Purchaser […], in accordance with the following (the “Buyout Option”): …” […] No Interest The Purchaser is not granted interest in any assets or Business IP of the Corporation. ... [Agreement 2] includes the following key provisions: Recitals “[…] the Purchaser wishes to acquire from the Corporation, […] a gross sales royalty […].” […] Gross Sales Royalty “As consideration for, […], the payment by the Purchaser of the Initial Installment and, if applicable, the Second Installment, […], the Corporation […] agrees to pay to the Purchaser a royalty amount ([…] a “Royalty Payment”) equal to […]% of monthly IP Revenue […] (the “Gross Sales Royalty”). […].” […] Minimum Royalties “[…] [No] Royalty Payment in respect of a calendar month will be less than $[…], […] referred to as the “Minimum Monthly Amounts”. […].” […] Buyout Option […], the Corporation may […] purchase and extinguish […]% […] of all amounts owing or to become owing to the Purchaser […] […] Acknowledgements of the Purchaser “The Purchaser acknowledges and agrees that: … (b) this Agreement and the royalties paid or payable […] do not confer on the Purchaser any right, title, or interest in any assets […] other than the rights to receive the payments set out herein.” […] RULINGS REQUESTED In relation to [Agreement 1], you would like to know: 1. ...

("[...] [Plan A]"), [...] and [...] ("[...][Plan B]"), [...]. 3. ... The Contracting Authority is identified as [...] ("[...] [the Contracting Authority]"), [...]. ... ("[...] [the Project Authority]") and is located in [...] [City 2]. ...

Directors of [the Corporation] * [...] [...][member type A] * [...] [...][member type B]; * [...][member type C]; * [...][member type D]; and * [...] ... • [organization] membership fees; • [...] fees; • [...][coach training] program fees; • Educational program registration fees ([...]); • Registration fees for [sport] events; • Hosting sanctions fees; • [Electronic] program fees; and • Fees for tangible personal property (e.g. [...]). ...

The sample contains the following information on the package: * Ingredients: […] * Contains: […] * Nutrition Facts: […] 4. ... Each piece measures approximately […] centimetres in diameter, and is about […] millimetres thick. […]. 9. ... It is […] similar to the type of texture commonly found in chips or crisps. * Cooking process: The Product is […], similar to other […] chips. * Size and shape: The Product is […] in shape. ...

[Company X's] parent company [...] issued the [...] and the [...] ... [Country X] (the exception consisting of [...] valued at $[...]) on behalf of [Company Y]. ... [Direct quote] thus supporting the input tax credit (ITC) claimed on the payment to [Company Y] ([#] of $[...] = $[...]). • [Company X] claimed the ITC of $[...] despite [Company Y] not issuing an invoice stipulating the amount of [...] ...

(FinanceCo), and [...] (Service Provider), [...] have entered into a [...] ... The first group of services are the [...] [A] Services (section [...] of the Agreement). ... A few examples of such services are provided below: • [...]: on-line application entry and processing of applications based on FinanceCo's selected criteria. • [...]: post cardholder financial adjustments such as balance and cash and finance charges. • [...]: creating cardholder file with account information such as account balance and posting all pending authorizations to cardholder accounts through on-line enquiry. • [...]: processing and rendering of billing statements. • [...]: embossing, issuing, reissuing and replacing cards. • [...]: on-line statements, account cycle and miscellaneous history. 7. ...

The goals of the Association are: •   To represent XXXXX. •   To provide continuing education programs XXXXX. •   To remain non-profit and to ensure all funds collected by the Association are returned to the membership for the betterment of the members. •   To provide certification for qualified members. •   To promote the career of XXXXX to the profession, the community and to government XXXXX. ... The Association has two membership categories: Voting Members •   XXXXX •   XXXXX Non-voting Members •   XXXXX •   XXXXX •   XXXXX Membership in the Association provides members with many benefits, including the following: •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX the total fee for membership in the Association is $XXXXX. ... Gaudet Charities, Non-Profit Organizations and Educational Services Unit Public Service Bodies and Governments Division Excise and GST/HST Rulings Directorate XXXXX  Legislative References: 123(1) "non-profit organization"; sections 17 & 18 of Part VI of Schedule V. ...

STATEMENT OF FACTS You submitted the following documents for our review: * Statement of Adjustments, […]. * […][Agreement A], signed and dated [mm/dd/yyyy]- only portions of this agreement were provided. * Statements on letterhead of […] indicating lease payments on each of [mm/dd/yyyy], [mm/dd/yyyy] and [mm/dd/yyyy]. * Land Transfer Tax Statement evidencing conveyance of property […]. * […][Lease Agreement]- an incomplete document: it does not identify the parties to the agreement nor is it signed or dated. ... (Footnote 3) * Tenant means [X] and its successors and permitted assigns. * Term means the initial term of the Lease as set out in […] (see below). ... Each statement sets out the following details: * Income Collected – […] $[…] * Expenses Incurred – […]$[…] Although the terms of the lease payments are not set out in the documentation provided, the statements suggest the lease is paid on a monthly basis. 7. ...

We understand that [...] (the "Lessee") has entered into an agreement to lease the following aircraft from [...] ... The details are as follows: Aircraft Type Model Number Serial Number Registration Number [...] [...] [...] [...] • The lease agreement for this aircraft is for a period beginning on [mm/dd/yyyy] and ending on [mm/dd/yyyy]. • This aircraft will be imported at the Airport of Entry ([...] ... /registration number [...]) has been held in Canada by the lessee under a lease with the lessor will be 21 months on [mm/dd/yyyy]. ...

According to the agenda you submitted, the Conference will consist of […][numerous] sessions on […] and […], a […] plenary presentation, an opening and welcomes session with keynote speakers, [#] plenary sessions, [#] parallel sessions, [#] brainstorming sessions and one session on the future [field of research] priorities, [#] sessions on […], one session on […], and [#] sessions for poster and sponsors exhibit. ... The last day has [#] sessions for a […] meeting on the [conference] outcomes and future [field of research] priorities. ... You are expecting [#- #] delegates, with more than 75% of these delegates coming from outside of Canada. 10. ...