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18 June 1997 GST/HST Interpretation HQR0000527[2]- Application of the GST to Supplies of Admissions to Annual Conventions Unedited CRA Tags ETA 123(1) admission; ETA 222(1); ETA 240(1)                                                                         Telephone #: (613) 954-5124 Fax #: (613) 990-1233 11690-1(crl) HQR0000527 ss. 123(1), 222(1), 240(1) XXXXX June 18, 1997 This is refers to your facsimile dated January 27, 1997, in which you requested information concerning the registration status of the XXXXX with respect to a convention which was held in Canada in XXXXX[.] Statement of Facts •   The District, a resident of Canada, was not (and is not currently) registered for the Goods and Services Tax (GST). •   The District holds a convention on an annual basis, hosted by a club in either Canada XXXXX. ... A registration form was subsequently submitted to the Department. •   When no reply was received, XXXXX contacted the Tax Services Office (TSO) and requested a ruling in regard to the convention. •   XXXXX was advised that the District should charge the GST and a provisional GST registration number was assigned to the District. •   The District collected the GST on the convention and the GST was recorded in the accounts, by the auditor. •   The TSO sent a letter to the District stating that it was not required to register but neither an explanation nor a ruling accompanied the letter. ...

[(the Company)] by [...] a painting service provider located in [...] ... In this case, the Company ships parts from their plant in [...] [City 1, Province X] (a non-harmonized province) to [...] (the "service provider"), a sub-contractor in [Province Y] (a harmonized province), for a painting process as described in Company purchase order #[...] and #[...] and service provider invoice #[...]. ...

We understand the following facts: 1. […] (“Distributor”) and Marketer are GST/HST registrants; 2. ... You have submitted sample contracts outlining the terms and conditions under which the Allowances are paid to Retailers by Marketer; Sample Contract No. 1 – […] 9. ... The Retailer, and not the Wholesaler, is the person who is entitled to be paid the Allowance pursuant to the agreement, and the Wholesaler receives the Allowance from Distributor on behalf of the Retailer; Sample Contract No. 2 – […] 15. ...

Subsection XXXXX of XXXXX indicates that the following documents should be considered as lifeguard certificates: •   XXXXX •   a certificate that XXXXX considers equivalent to the certificates mentioned in clauses (a), (b) or (c). 5. Subsection 17(10) of the Regulation indicates that the following should be considered as assistant lifeguard certificates: •   XXXXX •   any of the certificates mentioned in subsection 17(9); or •   a certificate that the XXXXX considers equivalent to a qualification referred to in clauses (a), (b) or (c). ... Venne Director Special Sectors GST Rulings & Interpretations c.c.: J. ...

The Charity currently has [#] [camps]: […][list of location of camps] 6. ... [Camp] seasonal program staff members participate in a pre-season training program. […] 14. […] 15. ... The factors the CRA takes into consideration in determining whether a recreational or athletic activity or program is intended to be provided primarily to individuals who have a disability include: * The purpose of the organization/program as set out in its governing documents; * How the organization/program is promoted or advertised; * The nature of the activities provided; * The qualifications of instructors/staff; * The ratio of staff to participants; * Whether healthcare services are provided as part of the program; * The nature design and use of the facilities; and * How participants in the program are selected. ...

FuelCo purchases jet fuel from […] and […][X] and [stores the jet fuel in a shared fuel storage facility “the fuel farm”] […]. ... Some of the NonResAir airlines are registered for the GST/HST, while others are not. 5. […]. […] (“Operator”), currently operates and manages the Airport fuel farm. 6. The fuel farm is used by […] and […][X], 2nd tier intermediaries such as FuelCo, and individual airline companies. 7. ...

You operate a […] (Business) based in […][Canada]. 2. […] [the] Business is registered for GST/HST […] with effective date of [mm/dd, yyyy] and Business Number […]. 3. ... The Project is described as […] 14. The following reward packages established by [the Business for the Project] received [funding] from [Y] […]: * […][Description of items included in each package] 15. […][Information on the delivery of Project reward packages to Y]. 16. […]. ... The elements included in each of the [reward] packages established by the Business are described […] on the Platform […]. ...

The association also provides information about XXXXX medicine and provides referrals to member XXXXX doctors across Canada. •   Members of the Association receive: •   a Guide to the Ethical Conduct of XXXXX Physicians; •   Standards of Practice that have been developed by the association; •   the association's quarterly newsletter, XXXXX, which provides a forum for sharing knowledge and information among members; •   a complimentary subscription to the XXXXX[;] •   a special discount to the XXXXX[;] •   a membership directory; •   brochures and promotion material for member's use at cost. ... The association develops and implements public relation strategies with regards to government, the public and other professions; •   a political link between the profession and federal government •   a common forum where members can share and exchange information with suppliers and business contacts at the annual general meeting; and •   a vote at the annual general meeting or any special meetings called by the Board of Directors. •   Annual dues are as follows: XXXXX[.] •   Membership in the Association is not necessary in order for individuals to maintain their professional status. ... These are, in summary: •   an indirect benefit intended to accrue to all members (whether or not all members, or only a few, actually do benefit from it); •   investigation, conciliation and similar services for settling disputes among members; •   the right to vote and participate in meetings; •   the right to purchase property or services at their fair market value; •   the right to membership discounts, where the total value of the discounts is insignificant (i.e. less than 30%) relative to the membership dues; and •   newsletters, reports and publications that are insignificant in value relative to the membership fee or that contain information on the body's activities and financial status and that may be significant in value but for which no fee is normally charged to non-members. ...

BACKGROUND We understand that you are providing services as a[n] […] acupuncturist in the provinces of […] through your business, […]. You are registered for GST/HST as a sole proprietor under the business number noted above. […]. The services you provide are not payable or reimbursed by a provincial health insurance plan. […]. ...

1 June 1996 GST/HST Interpretation 11820-3[2]- The Visitor's Rebate Program Unedited CRA Tags ETA 252(1); ETA 132(1)                                                                         File # 11820-3(MB) Doc # 2893G Ref: Ss 252(1) & Ss 132(1) XXXXX Subject: The Visitor's Rebate Program Dear XXXXX This is in response to your telephone conversations with a member of my staff and your letter of April 18, 1996, concerning the eligibility of XXXXX on permanent assignments in XXXXX to receive a GST Visitor's rebate on items purchased when they periodically return to Canada on leave or temporary duty. ...