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1 March 1996 GST/HST Interpretation 11650-2- Approval and Acceptance of Annual Blended Rates for the Purposes of Claiming Input Tax Credits (ITC's) Under the Excise Tax Act (the Act) Unedited CRA Tags ETA 169; ETA 141.01                                                                         File #: 11650-2(on)                                                                         c.n. 2486(GEN)                                                                         s. 169 & 141.01 XXXXX March 1996 Dear Sir: I refer to your letter of June 8, 1995, requesting the approval and acceptance of annual blended rates for the purposes of claiming input tax credits (ITC's) under the Excise Tax Act (the Act). ...

The following documents were submitted for our consideration: * Form GST386, Rebate Application for Foreign Conventions, on which [Company A], a non-resident located in […][Country Z] claimed a FCTIP rebate of $[…] as the organizer of a foreign convention. ... The invoices for the hotel accommodations were not included. * A letter from [Company A] describing the purpose of the meetings. ... The program agenda indicates that the following activities took place over the period from [mm/dd] to [mm/dd/yyyy]: * Arrival in [City 1] on […] [Day 1] * [Day 2] […] [describes included tours, networking lunch and dinner]. * [Day 3] […] [describes included tours, networking lunch and dinner]. * [Day 4] Travel to [City 2]. […] [describes included tours, networking dinner]. * [Day 5] […] [describes included tours, award dinner]. * [Day 6] Departure from [City 2] […]. […][Interpretation Given] In order for an event to qualify as a foreign convention for purposes of the FCTIP, it must first be established that the event is a convention for GST/HST purposes. ...

The Gross Revenue is defined in Article [...] to mean [...]. Article [...]. 3. ... (iFootnote 1) After the first [...] years of the term, the rent payable by the Trust is equal to the greater of $[...] and [...] % of the Gross Revenue. The Gross Revenue is defined in Article [...] to mean [...]. Article [...]. 11. ...

In your letter of [mm/dd/yyyy], you provided a further detailed explanation […] of the responsibilities, role and functions of [the Dealer] in the industry context, an example, a Sample Referral Agreement and enclosed the following additional documentation: * Subscription Agreement between […][ACo] and Investor (the [A] Agreement); * Subscription Agreement between […][BCo], […][CCo] and Investor (the [B] Agreement); * […]. You also referred us to […] copy of the publicly-filed agency agreement between [BCo] and [CCo], […], […] and […] (collectively called the Agents) ([C] Agency Agreement) referred to in the above-noted [B] Agreement. ... [A] Agreement 13. […] [Under the] [A] Agreement […] between [ACo] (the Corporation) and an investor (the Investor)[,] […] the Investor may subscribe to purchase a specific number of shares or warrants of the Corporation. ...

The supplies made by the Corporation to owners and lessees of the units include the following: •   Electricity •   Repairs and maintenance •   Groundskeeping •   Garbage removal •   Insurance •   Management fees •   Water and sewer •   Snow removal and street cleaning[.] 6. ...

Un organisme déterminé de services publics, un organisme de bienfaisance ou un organisme à but non lucratif admissible a droit à un remboursement de la TPS qui correspond au " pourcentage établi " de la " taxe exigée non admise à un crédit " relative à un bien ou à un service pour sa période de demande. ... Toutes ces conditions doivent être respectées pour que la première condition de la définition " d'établissement admissible " soit respectée. ... Subvention admissible Pour respecter la deuxième condition de la définition d'" établissement admissible ", il faut que l'organisme reçoive une somme, sauf une somme symbolique, à titre de " subvention admissible ". ...

Based on the information you provided, we understand that chelation therapy involves the intravenous ("IV") administration of the chemical ethylene diamine tetracetic acid (referred to as "EDTA"), combined with other chemicals, that is used for various purposes as well as to address a variety of symptoms, such as: •   A preventative measure to avoid coronary artery surgery; •   A preventative measure to avoid amputation in cases of leg ulceration and gangrene; •   Hardened or blocked arteries; •   Angina pain; •   Leg cramp pain; •   Elevated blood pressure; •   Elevated blood cholesterol; •   Diabetes; and •   Macular degeneration of the eye. ...

We understand that chelation therapy involves the intravenous ("IV") administration of the chemical ethylene diamine tetracetic acid (referred to as "EDTA"), combined with other chemicals, that medical practitioners may use to for a variety of purposes and to address a variety of symptoms, such as: •   A preventative measure to avoid coronary artery surgery; •   A preventative measure to avoid amputation in cases of leg ulceration and gangrene; •   Hardened or blocked arteries; •   Angina pain; •   Leg cramp pain; •   Elevated blood pressure; •   Elevated blood cholesterol; •   Diabetes; and •   Macular degeneration of the eye. ...

We understand that chelation therapy involves the intravenous ("IV") administration of the chemical ethylene diamine tetracetic acid (referred to as "EDTA"), combined with other chemicals, to address a variety of symptoms, such as: •   A preventative measure to avoid coronary artery surgery; •   A preventative measure to avoid amputation in cases of leg ulceration and gangrene; •   Hardened or blocked arteries; •   Angina pain; •   Leg cramp pain; •   Elevated blood pressure; •   Elevated blood cholesterol; •   Diabetes; and •   Macular degeneration of the eye. ...