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27 April 1999 GST/HST Ruling HQR0001489- Application of the GST/HST to Business and Financial Transactions for the Hiring of Temporary Workers Unedited CRA Tags ETA 123(1) permanent establishment; ETA 132(3); ETA 142; ETA 165; ETA Sch VI, Part V, 7 GST/HST Rulings and Interpretations Directorate Place Vanier, Tower C, 10th Floor 25 McArthur Avenue Vanier, ON K1A 0L5XXXXX XXXXXAttention XXXXX Case: HQR0001489File #: 11680-7April 27, 1999 Subject: GST/HST APPLICATION RULING Transaction Between XXXXX Dear XXXXX Thank you for your letter of December 2, 1998, received by facsimile, and your subsequent letter dated December 22, 1998, together with the relevant agreements, concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the transaction(s) described below. ...

., CHE Municipalities & Health Care Services Unit Public Service Bodies and Governments Division GST/HST Rulings and Interpretations Directorate c.c.: O. ...

Yours truly, Jacqueline Russell Technical Officer Goods Unit General Operations & Border Issues Division Excise and GST/HST Rulings Directorate Donna Harding XXXXX Legislative References: 213 Section 6 of Schedule VII Section 1 of Part III of Schedule VI NCS Subject Code(s): 11645-3-1 11850-3 ...

Section 189(a)(i) of the ETA provides that: "... where an amount is paid by a person to an organization as(a) a membership due paid to a trade union as defined (i) in section 3 of the Canada Labour Code...... the organization shall be deemed to have made an exempt supply to the person and the amount shall be deemed to be consideration for the supply. ...

A "supply" is broadly defined as "... the provision of property or a service in any manner, including sale, transfer, barter, exchange, license, rental, lease, gift or disposition" (All definitions referred to in this ruling are found in subsection 123(1).). ...

Yours truly, Shashi Fernando Municipalities and Health Care Services Unit Public Service Bodies & Governments Division Excise and GST/HST Rulings Directorate Legislative References: Subsections 141.01(2), 165(1), 169(1) and 259(1); paragraph 20(i) of Part VI of Schedule V. ...

We have enclosed for your consideration, a copy of Technical Interpretation Bulletin B-076, entitled " Proposed Rebate for Printed Books, Audio Recording of Printed Books, and Printed Versions Of Religious Scriptures Under the GST/HST. ...

It comes in a regular and a cocoa flavour;-    It is advertised as a "XXXXX ";-    The ingredients of the regular flavour are: XXXXX cereal, milk ingredients, sugar, hydrogenated palm kernel oil, dextrose, calcium carbonate, soya lecithin and artificial flavour;-    The ingredients of the cocoa flavour are: XXXXX cereal, milk ingredients, sugar, hydrogenated palm kernel oil, dextrose, cocoa, calcium carbonate, soya lecithin and artificial flavour;-    The bar is individually wrapped and weighs 23 grams;-    The bars are sold in a retail format of 8 bars per carton and a jumbo format of 24 bars per carton, and a foodservice display box format of 24 bars per carton[;]-    XXXXX[;]-    The product comes in three flavours: XXXXX, XXXXX XXXXX;-    It is sold in cartons of 4 or 12;-    The main ingredients are vegetables, water, and brown rice;-    The product is similar in appearance to a hamburger patty. ...

24 August 2000 GST/HST Ruling 7277/HQR0000883- Coupons Issued Under Co-promotion Agreement Unedited CRA Tags GST/HST Memoranda Series, Memorandum 1.4, Goods and Services Tax Rulings Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th Floor 320 Queen Street Ottawa, ON K1A 0L5XXXXX XXXXX XXXXX XXXXXXXXXXXXXXX Case: 7277/HQR0000883File #: 11755-7August 24, 2000 Subject: GST/HST APPLICATION RULING Coupons issued under co-promotion agreement Dear XXXXX: This is in response to the letter from XXXXX of your office, concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the facts described below. ...

Paragraph 20(d) of Part VI of Schedule V to the ETA exempts a supply made by government where the supply is "of a service of providing information in respect of, or any certificate or other document evidencing... any other status of a person," where "person" is defined in subsection 123(1) of the ETA to mean "... a corporation... or a body that is a society,... association,... or other organization of any kind. ...