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Subsection 10(1) of the Regulations provides, in part, that when there is to be a single final recipient of a supply of a computer-related service (such as Web site hosting) made by a particular supplier, and the recipient acquires the supply under an agreement with the particular supplier or another supplier, the supply is made in a particular province if the final recipient avails itself of the service at a single ordinary location in that province, and either •   the particular supplier maintains information sufficient to determine that location; or •   it is the normal business practice of the particular supplier to obtain information sufficient to determine that location. ...

30 June 1995 GST/HST Interpretation 11846-3[1]- Application of GST to Funding Received by the Unedited CRA Tags ETA Sch V, Part VI                                                                         11846-3 (LFR)  XXXXX Manager, Interpretation and Services                              XXXXX Tax Services Office XXXXX                                                                                 June 30, 1995 Dear XXXXX: This is reply to XXXXX enquiry of March 16, 1994 in which he asked whether we agree with the opinions expressed in his letter regarding the application of GST to funding received by the XXXXX. ... As indicated in Schedule B of the Agreement between the XXXXX and the XXXXX, " XXXXX. ... All of the activities carried out by the XXXXX are made in furtherance of its principal goal of providing confidential assistance, through counselling and other related services, to individuals experiencing personal problems (e.g. emotional/psychological concerns; marital/relationship conflict; drug & alcohol abuse problems). ...

17 July 1995 GST/HST Interpretation 11635-3- Link Between Consignment Sales and Carrying on Business in Canada Unedited CRA Tags ETA 240(3)(b)                                                                         11635-3 (gjor)  XXXXX Interpretations and Services  XXXXX District Office Excise/GST                                                                           July 17, 1995 This is in response to your E-Mail dated October 18, 1994, concerning the above subject. ... In that case, Geigy, a Montreal drug manufacturer which shipped annually about $450,000 worth of its product to British Columbia in response to orders received and filled in Montreal, was held not to be " carrying on business" in British Columbia. ... Jones Director General Tax Policy GST Rulings & Interpretations Policy and Legislation Branch- XXXXX sign-off: Mitch Bloom c.c.: Imposition Team G. ...

The application of the GST to the aforementioned supplies of real property by the XXXXX will be as follows: •   the sale of House A and the land reasonably necessary for its use and enjoyment as a place of residence will be exempt under section 2 of Part I of Schedule V to the Act, with excess land exempt under section 9 of Part I of Schedule V, •   the sale of the vacant lot will be exempt pursuant to section 9 of Part I of Schedule V, and •   the sale of House B and the land that was placed on the market in May of this year will be exempt pursuant to section 2 of Part I of Schedule V, with any excess land exempt under section 9 of Part I of Schedule V. 3. ...

22 October 1998 GST/HST Interpretation HQR0000589- Subdivision of Lot and Subsequent Sale Unedited CRA Tags ETA 123(1) builder; ETA 123(1) supply; ETA 191(1); ETA 196.1; ETA 208(2); ETA Sch V, Part I, 2; ETA Sch V, Part I, 9                                                                         GST/HST Rulings and Interpretations  Directorate Place Vanier, Tower C, 10th Floor 25 McArthur Road Vanier, Ontario XXXXX XXXXX XXXXX XXXXX Case: HQR0000589 XXXXX                 File: 11870-5; 118702; 11950-2; 11950-6 Attention: XXXXX October 22, 1998 Subject: GST/HST INTERPRETATION Subdivision of lot and subsequent sale Dear Mr. ... Secondary issues (a) & (b) XXXXX has provided us with comments on the facts and transactions in question. ... Yours truly, Michael Wolff Real Property Unit Financial Institutions & Real Property Division GST/HST Rulings and Interpretations Directorate Legislative References: Excise Tax Act, subsection 123(1) builder, supply Excise Tax Act, subsection 191(1) Excise Tax Act, section 196.1 Excise Tax Act, subsection 208(2) Excise Tax Act, Schedule V, Part I, section 2 Excise Tax Act, Schedule V, Part I, section 9 NCS Subject Code(s): 118702; 11950-2; 11950-6 ...

Is GST/HST applicable to the license fee as described in fact # 7 above? ... Explanation Paragraph 142(1)(c) of the ETA provides that a supply of intangible personal property (such as the right to attend a convention and banquet) is deemed to be made in Canada where "... the property may be used in whole or in part in Canada. ... Please note that the fact that the cost of the publication consistently costs more to produce than the revenues derived for it will not affect the tax status of the advertising service. #5 (No Ruling Given) Is GST/HST applicable to the license fee as described in fact # 7 above? ...

In the context of the arrangement in this case, it does not appear that the establishment obtains ownership of the crafts, nor that it is a recipient of a supply of the crafts, for various reasons including: •   The agreement between the parties does not contemplate, either explicitly or implicitly, a transfer of ownership of the crafts from the crafter to the establishment. XXXXX[.] •   There is no indication in the agreement that the establishment has agreed to purchase the crafts at any time. ... If crafts are sold through the booth, the establishment becomes entitled to charge a XXXXX fee to the crafter, which, in the context of the arrangement, would be analoguous to a commission. •   The sales fee is to be calculated as a percentage of the total value of the crafter's sales. ...

Interpretation Given This interpretation is based on the following assumptions: •   the LDC supplies the electricity to the retailer who, in turn, supplies the electricity to the consumer; •   the nature of the supplies made to the consumer under either billing option are that of separate supplies made by the retailer and the LDC, for example, supplies of electricity are made by the retailer and supplies of distribution services are made by the LDC, both of which occur simultaneously; and •   the LDC is not an agent of the retailer and vice-versa. ...

Compensation to XXXXX 11) XXXXX states that the XXXXX shall pay fees on a periodic basis to each XXXXX for XXXXX during the period. 12) XXXXX states that the XXXXX shall also fund the following costs, expenses and amounts subject to limits and restrictions set out in XXXXX of the Agreement: •   travel expenses incurred by the XXXXX in providing midwifery services pursuant to their respective XXXXX Agreements; •   fees incurred for engaging second attendants for births or obtaining the services of other persons as permitted by their XXXXX Agreements; •   malpractice liability insurance; and XXXXX 13) XXXXX states that the XXXXX shall use its best efforts to ensure that no woman to whom services are provided under the program is charged or pays any fee of any kind for such services unless the woman insists on paying for religious, cultural or other particular reasons. ...

A "residential trailer park" is defined in subsection 123(1) as a trailer park encompassing at least two sites, where: (a) substantially all of the sites in the trailer park are supplied under a lease, licence or similar arrangement, or are intended to be supplied under a lease, licence or similar arrangement, under which continuous possession or use of a site is provided for a period of at least • one month, in the case of mobile homes or other residential unit, or • twelve months in the case of travel trailers or motor homes, or similar vehicles that are not residential units; and (b) the sites would be suitable for use by occupants of a mobile home (whether or not the park in fact has mobile homes) as a place of residence of individuals throughout the year. ...