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STATEMENT OF FACTS We understand the following from […] [the] fax, additional documents including a sample […][agreement] (footnote 1) (the Agreement), the company’s website […], and [various] telephone conversations held between […] and […][CRA officials]: 1. […] ([…] [ACo]), […], is a non-resident corporation that is registered for the GST/HST under Subdivision d of Division V. 2. ... According to […] the Agreement: […] 14. [ACo] retains exclusive ownership of all applicable copyrights, trade secrets, patents, and other intellectual property rights in the Software according to […] the Agreement, […] […] 15. ... The [Representatives] shall pay any […] taxes, fees or duties […], including but not limited to, taxes due and owing on amounts due or collected from end-users to the [Representative]. […] 31. ...

Tour 1 includes [...] nights short-term accommodation in Canada in [...]. ... Tour 2 includes [...] nights short-term accommodation in Canada in [...]. ... Tour 6 includes other elements such as meals [...], air transfers between [...], and ground transfers [...]. 22. ...

[X] acquired […] vacant land […] for $[…] on [mm/dd/yyyy] in an arm’s length transaction. ... [Information about] Registration of clients […][in Program B]. [#] documents are developed upon [Program B] registration […][including]: […][Agreement B], and […][Document B]. 11. […][Terms of Agreement B]: […]. 12. […][Key points in Document B]: […] 13. ... Based on review of the Facility’s floor plan and our phone conversation of [dd/mm/yyyy], we understand the following: * [Program B] is mainly operated […][at] the Facility, which […][accommodates] […][# clients]. […][Information about accommodations at the Facility] * The following rooms [in the Facility] are also used by the [Program B]: […] * […][More information about administration of the Facility] 22. […] 23. […][A supplemental agreement] between the [Organization] and [X] dated [dd/mm/yyyy] [includes specific terms and] governs the funding and obligations between the two parties. […] 24. ...

In addition to the above user fees, the Authority also derives funding through municipal levies and provincial grants. […] […] The Regional Municipality […] 8. The Regional Municipality […] (the “Region”) is an upper-tier municipality […]. ... The Agreement 10. […], the Authority and the Region entered into a Service Agreement (the “Agreement”) […]. ...

Paragraph […] provided that the buyers agreed to pay a brokerage fee of $[…] (Fee) plus applicable GST and any other applicable tax. ... On [mm/dd/yyyy], the lawyers sent a letter to [the client] and the broker with an enclosed cheque for $[…] which sum represents the balance of the settlement monies of $[…], less the sum of $[…] for legal fees. ... On [mm/dd/yyyy], the broker issued a cheque to the company for the sum of $[…] ($[…] plus [$][…] GST less a deal fee of $[…].) ...

Statement of Facts • XXXXX. • XXXXX currently operates XXXXX locations in XXXXX as well as a XXXXX electronic commerce website that sells and delivers to its customers a host of goods and services XXXXX. • The business number for XXXXX. • XXXXX deducts amounts from money owed to its suppliers. ... " • XXXXX. • A sign card displays the description, original price, discount amount and after discount amount of the good as follows: XXXXX XXXXX XXXXX XXXXX g $19.99 Temporary price discount expiration 1/17/10-5.00 Price at register $14.99 • The bar code pertaining to the item is programmed to display a second line on the sales receipt relating to the temporary discount (a negative amount). • The sales receipt, like the sign card, shows the description, original price, and discount amount of the item. • The cash register receipt will display the purchase of this good as follows: XXXXX $19.99 XXXXX $ 5.00- Sub Total $14.99 GST $ 1.00 Total $15.99 • The current and past practice has been to charge GST/HST on the pre-discounted price. • The sum of the temporary discount granted to customers is tabulated by XXXXX and deducted automatically from payments owed to the respective vendors of the discounted goods. ... Since these negotiations are not a reaction to competition but rather planned discounts (often due to the supplier having a promotional allowance budget for this item), XXXXX. • XXXXX. • XXXXX. • XXXXX. • Effective XXXXX, XXXXX modified its procedure in order to systematically grant the discounts to all customers. ...

The Park is located at [...] in [...], in the municipality of [...], [...] ... The unit measures [...] x [...] feet. You had an addition measuring [...]' x [...]', also manufactured by [...], attached to the unit, providing a total living area of about [...] square feet. 8. ... You paid rent monthly, and you were temporarily away from the trailer park [...] during the winter, generally during [...]. 10. ...

The [...] Act was assented to on [mm/dd/yyyy]. 2. According to section [...] of the [...] ... Under section [...] of the [...] Act [...]. [direct quote from legislation] 5. Under section [...] of the [...] Act [...]. [direct quote from legislation] 6. ...

. / 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. ... On [mm/dd/yyyy], the Assignor and […](the Vendor) entered into an Agreement of Purchase and Sale ([…][the Agreement]) with respect to a residential condominium unit (the Unit) legally described as: […] with a municipal address of […]. 5. ... According to the Assignment Agreement: a) the Assignee was required to pay, to the Assignor, an assignment amount of $[…] for the assignment of [the Assignor’s] rights in [the Agreement]. […][An amount of]$[…] was payable [by the Assignee to the Assignor] as a deposit and the remaining balance of $[…] was payable [to the Assignor] on the Completion Date; b) the Assignee was required to pay, to the Developer, an assignment fee of $[…] plus [GST/HST]; c) the assignment amount included an amount to reimburse the Assignor for the Deposit of $[…] that was paid upon execution of [the Agreement] thus, the Assignor’s profit before commissions was $[…] (that is, $[…]- $[…] = $[…]); d) the Assignor was responsible for paying, to the Sub-agent, both the listing and selling agent portions of the commission in respect of the assignment of the Assignor’s rights in [the Agreement], which was a total of $[…] thus, the Assignor’s profit after commissions was $[…] (that is, $[…]- $[…] = $[…]); and e) the assignment amount (that is, $[…]) was inclusive of any [GST/HST] payable with respect to the assignment of the Assignor’s rights in [the Agreement], and the Assignor must remit any [GST/HST] payable. 13. ...

[The Municipality’s] [plan A] policies provide […] for […] Areas in addition to those set out in [plan B]. ... On [mm/dd/yyyy], [the Municipality] enacted and passed By-law [#] to amend the […], to establish […][a fee] of $[…] per […] request received from [mm/dd/yyyy] to [mm/dd/yyyy], inclusive. ... An application for an […] follows a similar, but separate, process from a […] request process. 15. ...