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Nous comprenons que: * […] (le « preneur ») a conclu une entente pour louer l’aéronef suivant de […] (le « bailleur »), un non-résident avec qui le preneur n’a aucun lien de dépendance. Type d’aéronef Numéro du modèle Numéro de série Immatriculation […] […] […] […] * Le contrat de location commence le [jj/mm/aaaa] et se termine le [jj/mm/aaaa]. * L’aéronef sera importé à […] le [jj/mm/aaaa] et sera exporté le [jj/mm/aaaa]. * Au terme d’un bail conclu avec le bailleur, le preneur ne doit pas détenir l’aéronef au Canada pendant plus de 24 mois. ... Veuillez agréer, […], l’expression de mes sentiments distingués. 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 ...

XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX XXXXX XXXXX •   XXXXXXXXX •   XXXXXXXXX •   XXXXXXXXX •   XXXXXXXXX •   XXXXXXXXX •   XXXXXXXXX XXXXX XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX XXXXX XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX Interpretations Requested 1. ... The XXXXX would appear to address two separate supplies: •   Supply by XXXXX, consideration for which is based on XXXXX total, and •   Supply of research services supplied by the Institutions. ... The determination of the value of the consideration in Canadian currency is made on: •   the day that GST/HST is payable; or •   such other day as is acceptable to the Minister. ...

When applying these facts, we are again in agreement with you that the total GST payable on the lease payment is determined to be $25.90 per month when using the three step approach: Step 1: Calculation of the Monthly Finance Charge Selling price of the new vehicle before GST: $20,000 Less: trade-in Allowance     5,000 Adjusted capital cost $15,000 Add: residual value   11,000 Finance Base: $26,000 Monthly Finance Charge: $26,000 (Finance Base) x.00782 (money factor) $      203.32/mth Step 2: Calculation of the Monthly Depreciation Charge Adjusted capital cost $15,000 Less: residual value   11,000 Depreciation Base: $  4,000 Monthly Depreciation Charge: $4,000 (Depreciation Base) ÷ 24 months:        166.67/mth GST Base: $     369.99/mth Step 3: Calculation of the GST Payable on the Monthly Lease Payment 7% x $369.99/mth (GST Base) $25.90/mth Example #3: (letter, July 30, 1996) Facts Provided: •   XXXXX (the "dealer") leases a new vehicle to a non-registrant; •   Lease period on the new vehicle leased from the dealer: 24 months •   Agreed value of the new vehicle: $20,000.00 •   Agreed value of the trade-in vehicle: $  5,000.00 •   Lien against the trade-in vehicle (owed to financial institution): $  2,000.00 •   Agreed credit given on the trade-in vehicle ($5,000- $2,000): $  3,000.00 •   Residual value (i.e., option price) on the leased new vehicle: $11,600.00 •   The monthly lease payment is calculated as follows:      Total vehicle price: $20,000.00      Less: agreed credit given on the trade-in vehicle     3,000      Net lease cost: $17,000      Monthly lease payment:      Net lease cost x acquisition factor ($17,000 x.047290) $      803.93      Less: residual value x residual factor ($11,600 x.037002)         429.22      Monthly lease payment: $      374.71 •   The monthly sales tax lease payment is calculated as follows:      Total vehicle price: $20,000      Less: trade-in allowance     5,000      Net sales tax lease cost $15,000      Monthly sales tax lease payment:      Net sales tax lease cost x acquisition factor ($15,000 x.047290) $     709.35      Less: residual value x residual factor ($11,600 x.037002)        429.22      Monthly sales tax lease payment $     280.13 •   The dealer then prepares an addendum to the lease which discloses the monthly lease payment, the sales tax lease payment, the amount of the lien and the GST payable as shown in Appendix C to your letter entitled XXXXX; •   Immediately after the lease is executed, the lease and the leased new vehicle are sold by the dealer to XXXXX. ... The vehicle subject to the lease is then sold by the dealer to the lessee for an amount equal to the residual value (i.e., $11,600); Response: •   We agree that the monthly GST payable calculated on the monthly sales tax lease payment (determined above and in Appendix C to your letter) will be equal to: 7% x $280.13/month = $19.61/month; •   We also agree that the dealer is required to collect GST from the lessee on the full consideration paid by the lessee to acquire the vehicle pursuant to the purchase option (i.e., 7% x $11,600 = $812); Example #4: (letter, July 30, 1996) Facts Provided: •   Same facts as example #3 except that the trade-in has an agreed value of $15,000 and a lien of $12,000 for a net trade-in allowance of $3,000 (and the lease payments remain at $374.71/month) Response: •   Using the same method of calculation and money factors provided in Appendix B to your letter, the sales tax lease payment will be calculated as follows:      Total vehicle price $20,000      Less: trade-in allowance   15,000      Net Lease Cost $  5,000      Lease payment:      Net price x acquisition factor ($5,000 x.047290) $     236.45      Less: residual value x residual factor ($11,600 x.037002)        429.22      Monthly sales tax lease payment $ Nil      Monthly GST payable (7% x $Nil) $ Nil •   Again, the dealer will collect GST in the amount of $812 (i.e., 7% x $11,600) from the lessee on the full consideration paid by the lessee to acquire the vehicle at the time the purchase option is exercised. Example #5: (letter, July 30, 1996) Facts Provided: •   XXXXX (the "dealer") leases a new vehicle to a non-registrant; •   Lease period on the new vehicle leased from the dealer: 24 months •   Agreed value of the new vehicle: $20,000.00 •   Agreed value of the trade-in vehicle: $11,000.00 •   Amount of the trade-in allowed by the dealer as a trade allowance $  7,000.00 •   Customer receives cheque for remaining value of the trade-in $  4,000.00 •   Lien against the trade-in vehicle: $Nil •   Residual value (i.e., option price) on the leased new vehicle: $11,600.00 •   Monthly lease payment to the customer on the leased new vehicle: $     185.55/mth Response: •   Proposed new subsection 153(4) of the ETA provides in paragraph (c) that the value of the consideration for the supply (i.e., the leased vehicle) is deemed to be equal to the value of that supply less "... the amount credited to the recipient in respect of the trade-in... ...

On [mm/dd/yyyy], [...] (the Individual) entered into a purchase and sale agreement (the Purchase Contract) with [...] ... On [mm/dd/yyyy], the final statement of adjustments was approved and became effective; it includes the following information: * Buyer- the Company, as bare trustee and nominee of the Individual; * Adjustment date- [mm/dd/yyyy]; * Completion date- [mm/dd/yyyy]; and * Possession date- [mm/dd/yyyy]. 5. ... The Real Estate Appraisal Division of CRA has provided the following information: * [...]- transfer of the Property from the Vendor to the Company, dated [mm/dd/yyyy]; * [...]- the borrower is the Company; digital signature is the Individual, as authorized signatory of the Company; * [...]- transferor/borrower/party is the Individual, as Covenantor (see below); * [...], includes the following:- borrower/mortgagor is the Company;- the Individual is "Covenantor"; the terms of the [...] provide, in part, that the Covenantor will pay or cause to be paid to the Mortgagee all amounts owing by the Mortgagor; to unconditionally guarantee full performance and discharge of all obligations of the Mortgagor; that the Covenantor is jointly and severally responsible with the Company. 7. [...]. ...

. / 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. ... No rebate is available with respect to a particular unit if the unit has a fair market value of $450,000 or more. […]. Please refer to the guide RC4231, GST/HST New Residential Rental Property Rebate for further information […]. ...

XXXXX: •   XXXXX; •   XXXXX; •   XXXXX; •   XXXXX; •   XXXXX; •   XXXXX; •   XXXXX; and •   XXXXX. ... The product literature states: XXXXX. •   XXXXX. •   XXXXX. •   XXXXX. •   XXXXX. ... Yours truly, Jacqueline Russell Goods Unit General Operations and Border Issues Division Excise and GST/HST Rulings Directorate 2006/06/21 — RITS 79779 — Tax Status of Osteopathic Manual Therapy Services ...

DOCUMENTS PROVIDED The summary of background facts in the next section is based on the following documents and correspondence: […][listing of documents submitted] SUMMARY OF BACKGROUND FACTS Key Services Provided and Ultimate Transaction * A summary of the key features in the foregoing documents, that would be relevant to the characterization of the services provided to the Company by the Service Provider, is set out in the attached […]. * The documents submitted […] relate to the services that the Service Provider agreed to provide to the Company in connection with a potential disposition of the Company's financial services operations, either by way of a sale of receivables, or a sale of […] shares, as well as entering into a […] program with a purchaser […]. * According to the Purchase Agreement […], the ultimate transaction took the form of a sale of assets of the Business, consisting of the […] Activity, the […] Products Activity and the […] Program (the Transaction; capitalized terms have the meaning set out in the Purchase Agreement; "transaction" in lower case refers to potential transactions in general, with respect to which the Service Provider was engaged). * While there are many descriptions of the Service Provider's role in the various documents, key elements of the descriptions may be summarized as follows: 1. Acting as a financial advisor, advice re evaluation of strategic alternatives including structure of the Transaction […] as demonstrated by: […]. 2. Assistance in searching for a purchaser […] and organizing the bidding process, including ongoing liaison and co-ordinating visits, as demonstrated by the following: […]. 3. ...

Facts XXXXX net tax = $5,600 for fiscal year 1995 •   In 1996 the registrant predicts the net tax to be owing as $4,000 which means there will be quarterly instalments of $1,000. •   The registrant makes instalment payments in March and June of $800. •   In June 1996 the registrant changes the fiscal year end to June 30 and files a return for January 1996 to June 30th 1996 for $2,200 net tax. ... In this case the appropriate interpretation for the calculation of the instalment base would be: •   similar to the above, the formula of subpara 237(a)(i) is inoperative since it requires the election made under subsection 248(3) to cease having application, •   under subpara. 237(2)(a)(ii) the net tax for the particular reporting period in this case is the period from July 1st 1996, to June 30th 1997, •   the formula under 237(2)(b) will take into consideration both the net tax for the twelve month period for 1995 ($5600) plus the immediately preceding period which is the short period of January to June 30th 1996, ($2200) which will result in an instalment base of C x 365/D or [($5600 + $2200) ÷ 365 (365 + 183)] = $5196 (rounded) •   Subsection 237(2) requires the instalment base to be the lesser amount of the above amounts which can only be determined once the net tax for fiscal year 96/97 becomes known. ... Research •   Q & A 8b.40 •   Q & A 6a.8 •   Explanatory notes ...

[the customer's] fridge as consumption normally takes place over the course of the next [...] days [...]; • The entire supply of the meal packages which use a [...] process will be further cold packed in a [...]. ... Appendix [...] of the submission is [listing of meal selections] Appendix [...] is [...] ... (includes HST) 2) Price shown with HST extra Price [...]% Price shown as HST & Delivery Separately includes delivery Taxes Total Alternative (A): Breakfast, Lunch Dinner $[...] [...] $[...] ...

The following information was provided […]: * […][The Association] is a non-profit professional association formed by volunteer practitioners in [yyyy]; * [The Association] has [#] members across Canada. The membership is comprised of […][list of the types of memberships available]; * [The Association] has developed a set of courses which are offered by certain authorized post-secondary institutions across Canada. […]; * The courses are generally offered as continuing education courses; * The courses are offered as credit courses at […][certain post-secondary institutions]; * [The Association] does not deliver any of the courses but authorizes the instructors for the courses; * When an individual completes a series of courses (or some equivalent) they may apply to [the Association] to be authorized to use the professional designation […]([…][Designation X]) […]; * […]; * [The Association] recently began offering […]([…][Exam Y]) that is a product of […][BCo]; * [The Association] charges a fee for administering [Exam Y] which is in excess of the minimum cost of administering the exam; * [Exam Y] is not recognized by any regulatory body; * Individuals who pass [Exam Y] are issued a […][Certificate Y]. ... We are unable to issue a ruling with regard to your enquiry as we have not received sufficient information to do so. […]. ...