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. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5 XXXXX XXXXX XXXXX XXXXX Case Number: 61722 Attention: XXXXX November 18, 2008 Subject: GST/HST RULING GST Treatment of Sale of Shares and Associated Rights to Use Land Dear XXXXX: Thank you for your letter of XXXXX, and your XXXXX, concerning the application of the Goods and Services Tax (GST) / Harmonized Sales Tax (HST) to supplies made under a shareholders' agreement. ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... Sale of the Facility Section 5 of Part I of Schedule V to the ETA exempts the sale of a multiple unit residential complex, or an interest therein, by a person who is a builder of the complex, or an addition thereto, where: • the last supply of the complex, or addition, by way of sale to the builder was either an exempt supply or a deemed taxable sale of the complex, or addition, under the self supply rules in subsection 191(3) or 191(4), unless- the builder substantially renovated the complex after the complex was last supplied to the builder, or- the builder claimed an ITC in respect of that last acquisition of the complex or addition, or in respect of an improvement thereto since that last acquisition, other than an ITC in respect of the construction of an addition to the complex. ...

17 August 1995 GST/HST Interpretation 11848-7 11846-3(LFR)- Tax Treatment of Services Provided to Victims of Crime Unedited CRA Tags ETA 165                                                                         11848-7(RCMP) 11846-3(LFR) XXXXX                                                                                 August 17, 1995 Dear XXXXX This is in response to XXXXX memorandum of July 21, 1994 (with attachments) in which she requested our opinion regarding the status of payments made by the Province of XXXXX to the City of XXXXX for its use in the operation of the XXXXX. ... " Schedule "A" to Agreement I states that the "Project Director will be responsible for the establishment and for the administration of the Program which will provide the Services to victims of crime in the area of: XXXXX Under Agreement II, XXXXX retains XXXXX as XXXXX, to provide the services set out in Schedule "A". ...

22 September 1995 GST/HST Interpretation 11849-1[1]- Application of GST to Administrative Services Supplied by the to the in its Capacity as                                                                         11849-1(LFR)  XXXXX                                                                                September 22, 1995  XXXXX Dear XXXXX This is in reply to XXXXX letter of May 4, 1994 to XXXXX of this Directorate in which he requested our views on the application of GST to administrative services supplied by the XXXXX to the XXXXX in its capacity as Trustee XXXXX (Trust Fund) x On April 7, 1994, XXXXX wrote to the XXXXX Tax Services Office seeking clarification regarding the status of supplies made to the Trust Fund by the XXXXX In his letter, XXXXX questions whether XXXXX is exempt from paying GST on XXXXX supply of administrative services to the Trust Fund since the services are purchased from a trust that is funded by the Government of XXXXX and the province is exempt from paying GST. ... Article 4.(2) of the RTA between Canada and XXXXX states that " The Province covenants that, where, in respect of any transaction, matter or thing, the Goods and Services Tax is imposed or levied and would be payable by a corporation or agency of the Province, if the Goods and Services Tax were applicable to such corporation or agency, the corporation or agency, except for those corporations or agencies listed in Schedule A, shall pay the Goods and Services Tax... ...

11 June 1997 GST/HST Interpretation HQR0000031- HST INTERPRETATION Time of Supply-- Service Providers Unedited CRA Tags ETA 152(1); ETA 138(1); ETA 128(1) XXXXX Case: HQR0000031 XXXXX File: 11665-4                                                                         June 11, 1997 Dear XXXXX Thank you for your memorandum of June 13, 1996 (with attachment) addressed to Les Jones concerning the time of liability for reporting the Harmonized Sales Tax ("HST") collected for XXXXX service providers, particularly with respect to the situation of XXXXX. ... This does not appear to be the case here as the services are provided directly through XXXXX telephony equipment, while XXXXX equipment acts only as a gateway to connect the customer to XXXXX 3) Liability of Contract / Liability for Payment- It is unclear from the facts whether XXXXX or XXXXX would be liable to the customer for a failure to provide the service. ...

Attached is a copy of form GST 26 " Election by a Public Service Body to Have an Exempt Supply of Real Property Treated as a Taxable Supply " for your completion and submission to the Department. ...

In this context, XXXXX would like the CCRA to confirm the following three corollaries that it has presented: Corollary #1: IMs in Canada — XXXXX pays GST on consideration and wants ITCs (investment advice as input to commercial activities of XXXXX; #2 offshore IMs (GST remitted in error by XXXXX on behalf of XXXXX pension plan, subsequently returned by way of rebate) — XXXXX wants a ruling to the effect that XXXXX does not have to self-assess GST because of paragraph 217(a)(i) of the ETA (supply is excluded from definition of "Imported taxable supply" where it is acquired for consumption, use or supply exclusively in the course of commercial activities of the person"); and #3 XXXXX wants ruling that it is entitled to full ITCs on GST paid to Canadian IMs)[,] and 3. ...