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The goals of the course include: •   XXXXX  XXXXX  XXXXX  XXXXX 15) The course covers the following topics: •   XXXXX  XXXXX  XXXXX  XXXXX  XXXXX  XXXXX  XXXXX  XXXXX  XXXXX  XXXXX 16) The XXXXX course for builders, renovators, inspectors, and designers and is offered i XXXXX sessions. ... The certificates state: •   " XXXXX- This is to certify that XXXXX has successfully completed the requirements for the XXXXX •   XXXXX This certifies that XXXXX has successfully completed this training program." •   " XXXXX This certifies that XXXXX has successfully completed this training program. ...

Selling price of new vehicle $21 000.00 Less: Residual value (buy out option) 10 600.00 Net difference $10 400.00 Less: Trade-in allowance 5 000.00 Amount depreciated over 36 term lease (LDV) $  5 400.00 Add: Loan repayment $0.00 Gross amount owed to lessor by lessee $  5 400.00 Monthly lease payment Monthly depreciation ($5,400/36) $     150.00 Add: Interest charge 88.90 $     238.90 Add: GST ($238.90 x 0.07) 16.72 Total amount per month lessee remits to lessor   $     255.62 Response: The above calculation of the amount of GST on each lease payment ($16.72) is correct. ... Selling price of new vehicle $21 000.00 Less: Residual value (buy out option) 10 600.00 Net difference $10 400.00 Less: Trade-in allowance 5 000.00 Amount depreciated over 36 term lease (LDV) $  5 400.00 Add: Loan repayment $  3 000.00 Gross amount owed to lessor by lessee $  8 400.00 Monthly lease payment Monthly depreciation ($5,400/36)  $     150.00 Add: Interest charge 88.90 $     238.90 Add: GST ($238.90 x 0.07) 16.72 Amount per month lessee remits to lessor re lease $     255.62 Monthly loan payment Monthly principal repayment (3,000/36) $       83.33 Add: Interest factor for loan amount 10.50 $       93.83 Total amount per month lessee remits to lessor $     349.45 Response: The above calculation of the amount of GST on each lease payment ($16.72) is correct. ... Selling price of new vehicle $21 000.00 Less: Residual value (buy out option) 10 600.00 Net difference $10 400.00 Less: Trade-in allowance Initial value $12,000.00 Amount of trade-in allowed on lease 10 400.00 Amount given to owner in cash $  1,600.00 Amount depreciated over 36 term lease (LDV) $         0.00 Add: Loan repayment $  8 000.00 Gross amount owed to lessor by lessee $  8 000.00 Monthly lease payment Monthly depreciation ($0) $         0.00 Add: Interest charge 70.00 $       70.00 Add: GST ($70.00 x 0.07) 4.90 Total amount per month lessee remits to lessor, re lease $       74.90 Monthly loan payment Monthly principal repayment (8,000.36) $     222.22 Add: Interest factor for loan amount 28.00 $     250.22 Total amount per month lessee remits to lessor $325.12 Response: The above calculation of the amount of GST on each lease payment ($4.90) is correct. ...

. / 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. ... The Class B Limited Partner’s only activity is its investment in the Partnership; it is not a member of the Partnership Advisory Committee. 4) Pursuant to section […] of the Partnership Agreement, in addition to the distributions to be made pursuant to sections […], […] and […] of the Partnership Agreement when a general partner resigns or is removed, or the Partnership is sold or dissolved, the Partnership will, subject to section […], make a distribution to the holders of Class B Units and Class C Units (the “Priority Distribution”) in proportion to their ownership of Class B Units and Class C Units equal to an undisclosed specified percentage per annum of an undisclosed factor. 5) Pursuant to section […] of the Partnership Agreement, the general partner is required to make distributions to the partners from time to time- that is, essentially all sums received from eligible investments, net of: the payment or reimbursement of the partnership expenses, which includes the payment of management fees, […] and other types of fees pursuant to section […], and the payment of the Priority Distribution. 6) Section […] of the Partnership Agreement provides that amounts distributed shall be distributed to the partners as follows: * first, to the holders of Class B Units and Class C Units in proportion to their ownership of Class B Units and Class C Units, until such time as the holders of Class B Units and Class C Units have received all due and unpaid Priority Distributions; * as to the balance: […]% to the general partner and […]% to the limited partners in proportion to their ownership of Class A Units. ... You state that the management fee payable to the Manager under the Management Agreement and referenced in section […] of the Partnership Agreement is subject to the GST/HST. ...

XXXXX: •   XXXXX; •   XXXXX; •   XXXXX. 9. XXXXX. 10. The proposed fee for the XXXXX Camp is $XXXXX per participant. ... Daily activity choices within the camp program include: •   waterfront XXXXX •   adventure XXXXX •   sports XXXXX •   service XXXXX •   arts XXXXX •   science and technology XXXXX •   out-trips XXXXX. 12. ... Yours truly, Debra Murphy Charities, NPO & Educational Services Unit PSB & Governments Division Excise and GST/HST Rulings Directorate 2006/02/08 — RITS 60810 — [ITC for Tax on Imported Goods] ...

It owns $[…] of equipment (i.e., property) that it leases to customers. ... FinanceCo earns $[…] of exempt revenue from its loan activities and $[…] of taxable revenue from its leasing activities per year. 5. ... The value of this property, based upon book value, is $[…]. 6. It is your view that FinanceCo last manufactured, produced, acquired or imported substantially all of its equipment for consumption, use or supply exclusively (i.e., […][90% or more]) in the course of FinanceCo’s commercial activities based on the following: * property held by FinanceCo (other than financial instruments) is worth $[…]. * $[…] of that property is supplied exclusively in the course of FinanceCo’s commercial activities (leasing). * the remaining $[…] was not last manufactured, produced, acquired or imported, all or substantially all, for consumption, use or supply exclusively in the course of its commercial activities. ...

Facts •   XXXXX XXXXX[.] •   XXXXX provides advisory services exclusively to its two subsidiaries; XXXXX[.] •   During 1994 with respect to advisory services from the XXXXX and XXXXX[.] •   The two subsidiaries are incorporated under the XXXXX and operate under the XXXXX as venture capital funds deriving their revenue from interest, dividends, fees, et cetera. •   All the issued and outstanding common shares of XXXXX are owned by XXXXX[.] •   XXXXX[.] •   According to the XXXXX offering memorandum, investors who subscribe for one or more bonds may qualify for Canadian permanent resident status along with their spouse and dependents. Investment is required for a minimum number of years.      Also according to the memorandum, the "main purpose of the Fund is to provide equity or loan capital to establish, purchase, or maintain eligible businesses or commercial ventures,..."[.]      XXXXX[.] •   As established in a telephone conversation with XXXXX, on August 17, 1995, XXXXX is not and has not been charging GST on its supplies of advisory services to the funds. ...

12 January 1995 GST/HST Interpretation 11925-1[5]- Whether (Operating Under the Name), is Entitled to Claim the Transitional Special GST Credit Available Under the Excise Tax Act (ETA) to Certified Institutions Unedited CRA Tags ETA 230.2                                                                         File 11925-1                                                                         Doc. 499                                                                         Leg. ... Analysis Institutions that were certified pursuant to Part XIV of Schedule III and that are registered for the purposes of the GST are entitled to claim a special GST credit on a declining basis as follows: •   100% of the GST collectible in 1991 on the sale of specified property manufactured by handicapped individuals, •   75% in 1992, •   50% in 1993, •   25% in 1994, •   25% in 1995 and •   0% for calendar years after 1995. ... Venne Director Tax Policy- Special Sectors GST Policy and Legislation             XXXXX             J. ...

1 October 1996 GST/HST Interpretation 11680-7[4]- Application of Drop-shipment Provision to Supplies of Film Prints Unedited CRA Tags ETA 179(2); ETA 179(4)                                                                         Telephone #: (613) 954-8585 Fax #: (613) 990-1233 XXXXX                                                                                 File #: 11680-7(glr) XXXXX                                                                                 HQR0000124 XXXXX                                                                                 s. 179 ATTENTION: XXXXX I refer to XXXXX memorandum of August 7, 1996, regarding the possible application of the drop-shipment provisions in subsection 179(2) and (4) of the Excise Tax Act to supplies made by XXXXX to XXXXX. ... Jones' letters dated May 1, 1996 (File #: 11680-7(glr)), and June 6, 1996 (File #: 11680-7(glr)), on the same subject. ...

Our understanding of the facts is as follows: •   The College is a public college as defined in subsection 123(1) of the Excise Tax Act (ETA). ... For periods prior to January 1, 1997, the College would have been considered a charity for purposes of the ETA. •   The XXXXX has entered into an agreement with the College to purchase apprenticeship training courses for delivery to specified third parties (apprentices) according to training standards established by the XXXXX. •   XXXXX •   XXXXX. •   XXXXX §   XXXXX §   XXXXX §   XXXXX. •   XXXXX. •   The College has filed an election under section 6 of Part III of Schedule V to the ETA to deem the supply of Apprenticeship courses to be taxable for GST/HST purposes. •   The courses provided by the College under the Apprenticeship program do not have equivalency for credit courses. •   There are situations where a student may be granted exemption for a credit course in a degree or diploma program, but this is evaluated on a case-by-case basis. ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... Nous comprenons que: • XXXXX. (le " preneur ") a conclu une entente pour louer l'aéronef suivant de XXXXX (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 XXXXX XXXXX XXXXX XXXXX • Le contrat de location commence le XXXXX et se termine le XXXXX. • L'aéronef sera importé à XXXXX au plus tard le XXXXX et sera exporté le XXXXX. • Au terme d'un bail conclu avec le bailleur, le preneur ne doit pas détenir l'aéronef au Canada pendant plus de 24 mois. ...