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DATE January 21, 2013 TO [Addressee] FROM Dwight Kostjuk Senior Rulings Officer Aboriginal Affairs & Educational Sectors Unit PSBs & Governments Division Excise & GST/HST Rulings Directorate   FILE 146225 SUBJECT : GST/HST INTERPRETATION- Application of GST/HST to a Supply of a Legal Service Performed in Large Part on a Reserve and Provided to an Indian Individual […][Scenario A] A lawyer is based on a reserve.  ... A part of […] [the lawyer's] services do not occur on a reserve.  ... Interpretation Provided It is our understanding […] that the recipient of the legal service is the Indian individual and is not the Government of Canada. […]. ...

This interpretation letter also acknowledged that XXXXX was not carrying on business in Canada for GST/HST purposes. •   XXXXX which is a corporation resident in Canada and registered for GST/HST purposes, operates a XXXXX. •   XXXXX. •   XXXXX. •   XXXXX. •   The XXXXX were imported between XXXXX. •   XXXXX was the importer of record of the XXXXX and paid GST at time of importation. •   Title to the XXXXX transferred from XXXXX when the XXXXX arrived at XXXXX. XXXXX did not take ownership of the XXXXX. •   XXXXX. •   XXXXX. Interpretation Requested Does the ITC relief mechanism under section 180 of the Act apply with respect to the GST paid on the XXXXX at the time of importation? ... Leyton Border Issues Unit General Operations and Border Issues Division Excise and GST/HST Rulings Directorate 2006/01/09 — RITS 55422 — [New Residential Rental Property Rebate] ...

We understand that: • [...] (the "Company") is a GST/HST registered company located in [...] ... The company provides [...] services in [...] for companies importing into Canada. • The Company's clients include GST/HST registered non-resident importers that do not have a physical presence in Canada. ... Yours truly, Carolle Mercier Unité des questions frontalières / Border Issues Unit Division des opérations générales et des questions frontalières / General Operations & Border Issues Division Direction de l'accise et des décisions de la TPS/TVH / Excise and GST/HST Rulings Directorate UNCLASSIFIED ...

1 June 1996 GST/HST Interpretation 11690-8[2]- Legislative Amendment Brought to Section 240 Unedited CRA Tags ETA 240(3)(b)                                                                         Telephone #: (613) 954-8585 Fax #: (613) 990-1233 File #: 11690-8(dc) Para. 240(3)(b) XXXXX I refer to XXXXX inquiry of May 14, 1996, from your staff, which was sent to me by fax, concerning the legislative amendment brought to section 240 of the Excise Tax Act (Act), in connection with the voluntary registration available to non-residents for GST purposes. ... In addition, non-residents are entitled to register voluntarily if they enter into agreements to supply: •   services to be performed in Canada, or •   intangible personal property to be used in Canada, or that relates to real or tangible personal property situated in Canada, or to services to be performed in Canada. ... Jones Director General Operations & Border Issues GST Rulings and Interpretations Directorate Policy and Legislation Branch GOBI#: 2989(GEN) c.c.: R. ...

. •   The XXXXX Menu option is oriented toward clients who are looking for:-    a wide variety of foods provided for them-    the structure of a planned meal-    choosing the items they enjoy the most. •   The XXXXX Menu option is oriented toward clients who are looking for:-    quick, convenient and portable menus-    instant nutrition via the convenience of items such as drinks, snack bars and soups-    a dinner option of either company entrees or preparing their own food. ... You also submitted labels for each of these products and each label indicates the product is a nutritional supplement. •   XXXXX Chocolate Flavoured Drink Mix •   XXXXX Strawberry Flavoured Drink Mix •   XXXXX Wildberry Flavoured Drink Mix •   XXXXX Hot Chocolate Drink Mix •   XXXXX Smoothie •   XXXXX Smoothie •   XXXXX Cream of Chicken Soup Mix •   XXXXX Bar Chocolate Flavoured •   XXXXX Bar Chocolate Mocha Flavoured, and •   XXXXX Bar Honey Nougat. ... Products which qualify and are labelled as nutritional supplements pursuant to the Food & Drugs Act ("F&DA") and its Regulations are considered to be basic groceries pursuant to section 1 of Part III of Schedule VI to the ETA. ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... The associations are: •   XXXXX; •   XXXXX; •   XXXXX; •   XXXXX; •   XXXXX; •   XXXXX; and •   XXXXX. ... Yours truly, Nadine Kennedy, CMA Charities, Non-profit Organizations and Educational Services Unit Public Service Bodies and Governments Division Excise and GST/HST Rulings Directorate 2005/12/08 — RITS 50398 — [Application of the GST/HST to the Provision of Property and Services to Individuals Living at a Long-term Residence for Seniors] ...

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. ...

. / 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. ... Pursuant to this subsection, • if the tax amount calculated includes a fraction of a cent and the fraction is less than half of a cent, the fraction may be ignored; and • if the tax amount calculated includes a fraction of a cent and the fraction is equal to or more than half of a cent, the fraction must be increased to a full cent. ... As such, either of the following calculations is acceptable. $31.95 x 13% = $4.1535 = $4.15 $31.95 x 5% = $1.5975 = $1.60 $31.95 x 8% = 2.5560 = 2.56 $4.16 Subsections 165.2(1) and (2) read as follows: 165.2 (1) Calculation of tax on several supplies- Where two or more taxable supplies are included in an invoice, receipt or agreement and tax under section 165 is imposed in respect of each of those supplies at the same rate or rates, the tax payable in respect of those supplies, calculated on the consideration for those supplies that is included in the invoice, receipt or agreement, may be calculated on the total of that consideration. (2) Rounding of tax- Where tax that is at any time payable under this Division in respect of one or more supplies included in an invoice, receipt or agreement is an amount that includes a fraction of a cent, the fraction (a) if less than half of a cent, may be disregarded for the purposes of this Part; and (b) if equal to or greater than half of a cent, shall be deemed, for the purposes of this Part, to be an amount equal to one cent. ...

The two legal entities that would like to make the section 156 election are: •   XXXXX ("H Co. ... H Co. is owned by three non-resident XXXXX legal entities: •   XXXXX having an XXXXX% interest; •   XXXXX having a XXXXX% interest; and •   XXXXX having a XXXXX% interest. 7. ... A Co., a non-resident XXXXX legal entity, has a 100% ownership interest in: •   XXXXX; •   XXXXX; •   XXXXX 9. ...

. / 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. ... Whether the Government will reconsider the filing requirement for the Form RC4616 is a matter of tax policy, which is the responsibility of the Department of Finance. […]. […] […] The election under section 156 must be made jointly by a person that is a specified member of a qualifying group and another specified member of the same group and filed with the CRA. ... If you require clarification with respect to any of the issues discussed in this letter, please call […] Marcel Boivin, Director, Financial Institutions and Real Property at 613-952-9248. […] ...