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STATEMENT OF FACTS Based on the information you provided, our understanding of the facts is as follows: Parties involved: * […] (Vendor) – sets up ATM bank machines (i.e., sells equipment & related software licences), * […]([…][X]) – assignor and subsequently lessee, * […] (Lessor), a non-depository short term credit institution that provides primary equipment financing through leases – assignee and subsequent lessor All parties are registered for GST. Facts: * [X] enters into an “Acquisition Agreement” to acquire equipment & software licenses from the Vendor. * [X]’s acquisition of the equipment does not include the purchase of any software which is licensed to [X] by the Vendor. ... It is not clear how this particular taxable supply was accounted for, since the full Equipment Lease Agreement [#] was not submitted […]. […] […] [ABC] has referred to section 165 of the ETA to say that “every recipient of a taxable supply made in Canada” shall pay GST/HST based on the “value of the consideration for the supply”. ...

BACKGROUND INFORMATION From [...], we understand that the relevant facts are as follows: 1. [...] (the General Partner) is the sole general partner of [...] ([...] [Limited Partnership A]). ... The General Partner is also the general partner for two other limited partnerships: [...] ([...] ...

10 April 1996 GST/HST Interpretation 11640-2- Application of the GST to the Supply of Intangible Personal Property Unedited CRA Tags ETA Sch VI, Part V, 10                                                                         Tel. #: (613) 954-8585                                                                         Fax #: (613) 990-1233                                                                         Files #: 11640-2(dc)                                                                         Sch. ... Jones Director General Applications Division GST Rulings and Interpretations Policy and Legislation Branch Enclosures GAD #s: 1559 & 1570 (REG) c.c.: R. ...

Schedules [...] and [...] to the agreement outline the activities and specific responsibilities of the physician. ... Schedule [...] lists the medical services to be performed by the physician relating to: • Management, treatment and disposition of all patients of the Department; • Arranging for the admission, consultation and disposition on patients; • Arranging follow-up of patients with family physicians and specialists; • Reviewing diagnostic test results; • Taking regular calls and giving advice to physicians from referring facilities; • Ensuring documentation is maintained on patients; • Providing medical direction to ambulance personnel; and • Participating in the development and implementation of departmental quality of care initiatives. ... Major responsibilities are listed in Schedule [...] to the agreement and include: • Managing the provision of patient care related to the Department: ­ Ensuring the provision of medical services in the Department by medical staff, residents and students through review, analysis and evaluation of the work of members of the Department; ­ Establishing, reviewing and revising policies, procedures and guidelines related to patient care; and ­ Providing advice on medical equipment acquisition, maintenance and disposal. • Education and teaching: ­ Delivery of medical education programs in the Department; ­ Delivery of continuing professional learning programs of the Department in cooperation with the [...]; ­ Defining and contributing to the teaching and instructional programs of other health care programs; ­ Ensuring that education and teaching activities complement patient care within the Department; and ­ Contribute to the development of regional, national, and international networks to attract high quality clinicians, educators and students and to facilitate professional development and collaboration. • Research: ­ Encourage, facilitate and support research activities of the Department; ­ Encourage and facilitate the acquisition of external grant funding; ­ Ensure that department members follow approved research protocols and administrative procedures as required; ­ Support and encourage the publication of research results in journals and presentations at professional seminars; and ­ Promote teamwork and collaborative research activity. • Quality management: ­ Coordinate the establishment of quality standards and indicators of patient care, monitor clinical performance and undertake appropriate corrective action to strive for the attainment of appropriate standards in patient care; ­ Ensure that the Department and its members comply with all policies, bylaws, rules and regulations, and standards established by accreditation bodies; and ­ Manage any complaints involving departmental members. • Professional human resources: ­ Assist in the development and ongoing review of a medical human resource plan; ­ Recruit new members of the medical staff; ­ Advocate for adequate resourcing of Department members; and ­ Provide mentoring and annual performance evaluation of Department members. • General management: ­ Participate in program planning, coordinate the implementation of new programs and services and assist in their evaluation; ­ Annually prepare a written report of the Department's activities; ­ Establish and periodically update departmental policies and procedures; ­ Represent the Department on committees as required; and ­ Other duties as required. ...

[…]. […] according to the […][documentation] you provided, the policy is issued by the insurer to the owner (defined as the person who owns the new home), to provide insurance to the owner and not to the builder. […]. ... As indicated in that policy, new home warranty insurance provides coverage for certain defects in the residential complex. […]. […]. ... According to the builder agreement […], the builder agrees to […] and pay […][the] fee to the insurer at the onset of construction to enroll a particular home in a new home warranty program. ...

15 October 1998 GST/HST Interpretation HQR0001016- Penalty and Interest on Closely Related Group of Joint Filers MEMORANDUM TO: Brian Paynter Returns & Payments Assessments & Collections Branch FROM: David Crawford General Operations Unit General Operations & Border Issues Division Subject: Penalty & Interest on closely related group of joint filers This memo is in response to your e-mail of December 19, 1997 addressed to Pat McKinnon. The facts of your question are: •   One member of a closely related group of joint filers under ss. 228(7) is audited and the refund that the member claimed is reduced or negated. •   If that refund was applied to a debit on a related account, the "invalid" credit reverses back to the first account and causes a debit on the second account to attract penalty and interest. •   The question is who should be assessed and liable for penalty and interest? ... RESEARCH •   Forms GST 303A & GST 303B •   Policy P-140 •   OFFSET OF TAXES BY A REFUND OR REBATE (GST) REGULATIONS •   Q & As from database •   explanatory notes from GST database ...

. / 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. ... Issue 1 – Third Party pension expenses incurred by a participating employer of a pension plan SCENARIO: * […] ([…] [The Corporation]) is a registrant and a “participating employer” as defined in subsection 172.1(1). * The [Corporation] Pension Plan (the “Plan”) is a registered pension plan that governs a person that is a trust, and the trust is a “pension entity” of the Plan as defined in subsection 261.01(1). The pension entity is resident in Canada and a selected listed financial institution. * [The Corporation] entered into contracts with non-resident third parties (e.g., […] ([…] [A Co]) and […] ([…] [B Co])) to supply investment management services relating to “pension activities” (Footnote 1) of the Plan. ...

25 March 1996 GST/HST Interpretation 11690-1- Eligibility to Claim Input Tax Credits Unedited CRA Tags ETA 145                                                                         Telephone #: (613) 954-8585                                                                         Fax #: (613) 990-1233                                                                         File #: 11690-1(glr)                                                                         s. 145 XXXXX March 25, 1996 I refer to XXXXX note of June 9, 1995, addressed to Mr. ... I understand that: •   XXXXX is a member of a partnership that consists of two other personal law corporations (PLCs) and the law firm of XXXXX[.] •   XXXXX[.] •   The PLCs each have management companies that charge the PLCs management fees, including the Goods and Services Tax (GST). •   The PLCs were set up for the sole purpose of receiving the profits of the law firm. •   The disbursements made to the PLCs are made under the terms of a partnership agreement and are not made at arm's length under the Income Tax Act. •   All the above entities are currently registered for GST purposes. •   XXXXX denied ITCs for the period beginning September 9, 1994, and ending October 30, 1994. ... Ryhorchuk GAD #: 1321(REG) imposition Team ...

XXXXX •   The Committee does not have a board of directors. •   The Committee is not at arms length as it is responsible to the XXXXX and the Association. •   XXXXX. At the end of its existence the Committee must provide reports of its activities to XXXXX. •   The Association may be considered the parent body of the Committee but this is not known for certain. •   The Committee does not have its own seal. •   The Committee is not a separate legal entity. ... XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   The Association keeps records of the disbursements from the account for expenses incurred by the Committee. ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... The following information was presented in your letter. •   XXXXX. •   XXXXX. •   XXXXX. •   XXXXX. •   XXXXX. •   XXXXX. •   XXXXX. ... Leyton Border Issues Unit General Operations and Border Issues Division Excise and GST/HST Rulings Directorate 2004/10/01 — RITS 54077 — Recovery of the Goods and Services Tax (GST) That [Were] Paid to XXXXX on the Purchase of XXXXX Products for Resale ...