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The societies provide [supplies of] […]. The reason there are several societies is that there are different funders. […] The societies are each incorporated under the […] Act of [province A] […]. ... Under section […] of the […] Act, […]. Thus, as a society incorporated under that Act does not have capital that is divided into shares, it cannot be owned by another society and therefore cannot be closely related to another society for purposes of section 128. ... This would not likely be the case for a society which is engaged in the provision of exempt [supplies of] […]. ...

1 October 1996 GST/HST Interpretation 11640-3[7]- Application of GST to Telecommunication Services After April 23, 1996 Unedited CRA Tags ETA 141.1(2)(a); ETA 141.1(2)(b)(i) ETA Sch VI, Part V, 7; ETA Sch VI, Part V, 22.1                                                                         Telephone #: (613) 954-8585 Fax #: (613) 990-1233 File #: 11640-3(dc) Para. 142.1(2)(a) Ss. 7 & 22.1, Sch. ... With the proposed amendment brought to section 7 to replace current paragraph 7(a) — a service that is primarily for consumption use or enjoyment in Canada — the supply by the telecommunication carrier of a dedicated telephone line to NRCO would not be excluded from zero-rating under any paragraphs 7(a) to 7(g). ... Jones Director General Applications Division GST Rulings and Interpretations Directorate Policy and Legislation Branch GAD #: 697(GEN) c.c.: R. ...

(the Company) is incorporated under the laws and jurisdiction of the province of [...] and is located in [....]. ... The amount of the deduction is equal to the difference between the HST calculated on: • the Price of the exclusive product at the time the Company supplied the exclusive product to the Contractor, (i.e., 13% of $300 = $39 HST); and • the consideration paid by the Contractor (i.e., 13% of $0 = $0). ... The amount of the deduction is equal to the difference between the HST calculated on: • the Price of the exclusive product at the time the Company supplied the exclusive product to the Contractor (i.e., 13% of $350 = $45.50 HST); and • the consideration paid by the host (i.e., 13% of $50 = $6.50). ...

The City has […] defined benefit pension plans: […] (collectively the “Plans”). ... The preamble to section […] of the Policy states that a City employee, namely the General Manager […] for the City […] oversees administrative matters with respect to the Master Trust while the City’s […] essentially monitors the assets of the Master Trust in accordance with the duties described in paragraph […] of the Policy. 10. ... The investment manager is required, among other duties described in paragraph […] of the Policy, to invest the assets of the Master Trust in accordance with the Policy. […]. 12. ...

10 May 1999 GST/HST Interpretation 11872-2- Application of the GST/HST to the Operations of a Band Empowered Entity Unedited CRA Tags Technical Information Bulletin B-039R, GST Administrative Policy — Applications of GST to Indians TO: XXXXX XXXXX XXXXX FROM: Suzanne Leclaire Public Service Bodies and Governments GST/HST Rulings and Interpretations Directorate Subject: XXXXX Thank you for your letter of January 5, 1999, with attachments, concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the operations of the XXXXX[.] ... These above noted documents provide that: •   XXXXX is an incorporated body established through a XXXXX XXXXX of the XXXXX that have entered into service delivery agreements. •   the XXXXX[.] •   the XXXXX shall have the full and complete management, control and disposal of the affairs, property and funds of XXXXX has territorial jurisdiction on XXXXX which have initially been approved by the XXXXX to receive child welfare services from XXXXX and which have in effect a resolution of the band agreeing to the provision of child welfare services by the XXXXX[.] •   the objects of XXXXX include: •   to operate in all respects as a XXXXX within the meaning of any and all statutes of the XXXXX and regulations thereunder; •   to plan, develop, deliver, co-ordinate and administer services for children and families including guidance, counseling, support and other services to children and families; •   to do all things necessary for the protection of children; and •   to provide appropriate residential placements for children requiring such placements. ...

The Company is registered for GST/HST purposes. •   The Company's customers ("Customers") are primarily individuals who are not registered for GST/HST purposes. •   All Customers have an account ("Account") with the Company in order to rent movies. ... However, coupons are normally distributed free of charge, while the store credits at issue are provided in exchange for used videos / DVDs / games. ... Yours truly, Bao Tran Specialty tax Unit Financial Institutions and Real Property Division Excise and GST/HST Rulings Directorate 2005/12/07 — RITS 63876 — A Box of Cookies Packaged for Sale to Airlines and Institutions ...

However, as it is a designated hospital authority, the public institution would claim an additional GST/HST rebate of 33% for the non-creditable tax charged in respect of its purchases used in the operation of the public hospital as determined by the formula "A [x] B [x] C" provided in subsection 259(4), but substituting: •   the reference to "prescribed percentage" in element "A" of the formula with 33%, i.e., the applicable prescribed percentage of 83% less 50%; and •   the reference to "designated activities" in element "C" of the formula with activities engaged in by the person in the course of operating a public hospital. For instance, if the total non-creditable tax charged during a claim period for the purchase of medical supplies was $100 (GST), and the person used 60% of the medical supplies in the course of operating the public hospital and the remaining 40% in the course of operating the nursing home, the calculation of the GST rebate payable in respect of the purchase of the medical supplies would be as follows: •   claim 50% of $100 of total non-creditable tax charged PLUS •   an additional amount based on the formula "A [x] B [x] C" where: "A" is 33% (83% less 50%) "B" is $100 (total non-creditable tax charged) "C" is 60% (the extent to which the medical supplies are used in the course of operating the public hospital) = ($100 [x] 50%) + (33% [x] $100 [x] 60%) = $50 + $19.80 = $69.80- total rebate for the claim period for the GST paid on medical supplies The apportionment rules ensure that a person that is a public institution receives the GST/HST rebate at the prescribed percentage of 50% for its activities undertaken otherwise than in its capacity as a selected public service body. ...

1 October 1996 GST/HST Interpretation 11640-3[9]- Application of the GST to Telemarketing Services Supplied by a Non-resident Corporation Unedited CRA Tags ETA Sch VI, Part V, 5; ETA Sch VI, Part V, 7 XXXXX XXXXX XXXXX XXXXXATTENTION: XXXXX Telephone #: (613) 954-4585 Fax #: (613) 990-1233File #: 11640-3(glr) HQR0000126 s. 123, 132, 142 Sch. ... XXXXX requested a review of his proposed interpretation letter to XXXXX I understand that: •   XXXXX is a non-resident corporation incorporated in XXXXX[.] •   XXXXX provides XXXXX services on behalf of XXXXX throughout XXXXX[.] •   XXXXX contracts with a Canadian company, XXXXX located in XXXXX, to provide telemarketing services. •   These telemarketing services consist of XXXXX contacting people throughout XXXXX to solicit orders for XXXXX[.] When telemarketing calls are successful, they are relayed to the appropriate office in XXXXX and the applicable XXXXX is carried out by the operator responsible for that market. •   When XXXXX invoices XXXXX for the supply of the telemarketing services, the totals are shown in XXXXX XXXXX pays for these services in XXXXX[.] •   Although XXXXX has an administrative office in XXXXX all the services are performed in XXXXX and all revenue is generated in XXXXX[.] ...

En règle générale, les services fournis au Canada par un agent de voyage sont assujettis à la TPS de 7 % ou à la TVH de 15 %, à moins qu'ils ne soient détaxés, auquel cas ils sont assujettis à la taxe au taux de 0 % [lxv] 57. ... Par exemple, un agent de voyage situé à Ottawa vend, pour le compte d'une compagnie aérienne, un billet d'une valeur de 1 000 $ pour un vol intérieur assujetti à la TPS de 7 % et reçoit une commission de 10 %. ... Dans ce cas, l'agent facturerait un montant de 1 070 $ (le prix du billet, 1 000 $, plus 70 $ de TPS) au passager pour le compte de la compagnie aérienne pour la vente du billet. ...

Statement of Facts In your letter you provide the following example for our consideration: •   An automobile dealer (the "dealer") leases a vehicle to a non-registrant (the "lessee"); •   Agreed value of the vehicle: $20,000.00 •   Lease period on the vehicle leased from the dealer: 24 months •   Agreed value of the trade-in vehicle accepted by the dealer: $15,000.00 •   Outstanding lien on the trade-in vehicle: $12,000.00 •   Residual value on the leased vehicle: $11,600.00 •   Lease factor/Money factor: 11.25%/.0052346 •   Calculation of the Monthly Lease Payment to the lessee on the vehicle per Appendix A to your letter: $374.71/mth •   Calculation of the monthly Sales Tax Lease Payment to the lessee on the vehicle per Appendix B * to your letter: ($188.11/mth) •   Immediately after the lease is executed, the lease and the leased vehicle are sold by the dealer to XXXXX GST equal to 7% of the consideration paid by XXXXX to the dealer is collected by the dealer from XXXXX and added to the dealer's net tax for the relevant reporting period. ... Furthermore, XXXXX as lessor, collects and remits the GST payable in respect of any monthly payments made by the lessee under the lease; •   If at the termination of the lease, the lessee decides to exercise the purchase option contained in the lease, the lease and the leased vehicle are first sold by XXXXX to the dealer. ... Department's Position Firstly, please note that we have reviewed your determination of the vehicle's Monthly Lease Payment (Appendix A *) and the Monthly Sales Tax Lease Payment (Appendix B *) based on the above-mentioned facts and concur with your findings. ...