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The […] membrane is then rolled into the liquid asphalt. This process is then repeated for the 2nd ply of […] membrane and/or a tiger torch is used for the 2nd ply. 4. The roofing systems in question are manufactured by […] [Company B]. […] 5. ... Yours truly, Zubair Patel, CGA General Operations and Border Issues Division Excise and GST/HST Rulings Directorate     ...

La TVH s'applique dans les provinces participantes aux taux suivants: 13 % en Ontario et 15 % au Nouveau-Brunswick, à Terre-Neuve-et-Labrador, en Nouvelle-Écosse et à l'Île-du-Prince-Édouard. ... Nous comprenons que les faits que vous nous avez donnés sont les suivants (Footnote 1) […]: 1. ... Il s’agit donc d’une entreprise puisqu’elle est assimilable aux termes « toute affaires quelconques » tel qu’indiqué dans la LTA. ...

[the Additional Rate] paid by [...] [User Groups] to the City of [...]. ... The City of [...] (the "City") operates an arena, [...] (the "Centre"), with [...] ice [...] ... The City is the owner of the buildings and lands located at the Centre's premises, which are located at [...], [...] ...

[X] are generally administered by […], members of which are usually located in various parts of Canada, […]. ... The administrative agent may be a third-party […] firm or a self-contained office […]. […]. ... [Company A] provides […] services to […] from [Company A]’s office in […][City 1, Province 1], […]. ...

In accordance with the Terms and Conditions on the application form, Participants apply to attend […][# of workshops]; Participants do not have the option of applying to attend fewer workshops, […][or of choosing] which workshops, […], to attend. The other elements to the supply by [ACo], such as […], cannot be acquired separately by Participants, and they do not, on their own, satisfy Participants’ needs in learning […]. ... A supply of an admission, such as the right to attend a workshop or seminar, is considered to be a supply of intangible personal property for GST/HST purposes. […]. […], characterization of a supply [as a service or an intangible] is dependent upon the nature of the agreement between the supplier and recipient. […]. ...

Specifically, we received the following documents: a) […] (Lender 1) documents: i) […] (the Lender 1 Dealer Agreement), and ii) […] (the Lender 1 Contract); b) […] (Lender 2) documents: i) […] (the Lender 2 Dealer Agreement), and ii) […] (the Lender 2 Contract); c) […] (Lender 3) documents: i) […] (the Lender 3 Dealer Agreement), and ii) […] (the Lender 3 Contract); d) […] (Lender 4) documents: i) […] (the Lender 4 Dealer Agreement), and ii) […] (the Lender 4 Contract); and e) […] (Lender 5) documents: i) […] (the Lender 5 Dealer Agreement), and ii) […] (the Lender 5 Contract). ... The key provisions in the various agreements regarding customer financing are described in […]. ... The Dealer has entered into various Contracts with Customers ([…]) for the sale of motor vehicles. ...

The Product label states [...]. 4. The Product is sold in multiples of [...]. 5. ... The Product is available in [...] flavours; [...]. 7. The package of the Product is in English and French. 8. The Product's [...] ingredients are: [...]. 9. The Product's [...]. ...

Based on […], and a […] master concurrent lease agreement (the MCLA), our understanding of the key facts is set out below: Background – the concurrent leases 1. ... The […] MCLA has […][the Trust] as the Concurrent Lessee. […] 2. The Trust is a trust established under the laws of […][Province A] with its head office located in […][Province B]. ... The Prepaid Rent payable to the Lessor is based on […]. The Lessor remits the GST/HST payable by the Concurrent Lessee. 10. […][The] MCLA provides the calculations used to determine the Deferred Rent, which is […]. 11. […], the Lessor is generally appointed as Collection Agent. ...

We understand that the Corporation is currently engaged in business as […]. ... As part of the Service, the Corporation would: * obtain the required credit information from the Buyer; * complete the financing application form and submit the application to the Lender; * ensure the […] [Product A] is free of liens and similar encumbrances; * issue payment to the Seller for the amount financed once the financing application is approved and accepted by the Lender and the funds are transferred to the Corporation; and * provide any additional information or further assistance to the Buyer or the Seller. ... You provided two sample Contracts with your letter for our review: Contract 1, […], used by […] (Lender1); and Contract 2, […], used by […] (Lender2). ...

The relevant provisions of […][the Service Agreement] include: […] […][The subcontractor] is appointed by [the Financial Institution] to carry on the business of representing [the Financial Institution] in distributing [the Financial Institution]’s products. […] [The Financial Institution] agrees to provide certain property to [the subcontractor] […]. ... Generally, the provisions of subsection 141.02(17) will apply to prevent [the Financial Institution] from altering its ITC allocation method for the technology inputs for the fiscal years […] [year 2 and year 3]. […]. ... See the section of our analysis below entitled, “Use of new ITC allocation method for […] [year 4 to year 6]” for further explanation. 3. […]. ...