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Statement of Facts We understand the following facts from the fax XXXXX and other additional information you submitted. •   XXXXX is a United Sates company and is incorporated in the state XXXXX. •   XXXXX is not registered for GST/HST purposes. •   XXXXX. •   XXXXX has an office in Canada where the Canadian operations are managed. The office is located in XXXXX. •   XXXXX has a full time employee in Canada who manages these operations. •   XXXXX purchases goods in Canada, maintains an inventory of those goods in Canada and sells all of them XXXXX. •   XXXXX contracts with Canadian XXXXX to sell their goods XXXXX. •   XXXXX. •   XXXXX. •   XXXXX has a bank account in Canada. •   XXXXX. •   XXXXX. ... The factors that will be considered in determining whether a non-resident is carrying on business in Canada for GST/HST purposes are listed in enclosed Policy Statement P-051R2, Carrying on Business in Canada and include: •   the place where agents or employees of the non-resident are located; •   the place of delivery; •   the place of payment; •   the place where purchases are made or assets are acquired; •   the place from which transactions are solicited; •   the location of assets or an inventory of goods; •   the place where the business contracts are made; •   the location of a bank account; •   the place where the non-resident's name and business are listed in a directory; •   the location of a branch or office; •   the place where the service is performed; and •   the place of manufacture or production. ...

[Individual A] and [...] [Individual B] held (otherwise than as a partnership) title in joint tenancy to [#] parcels of land in [...] ... The parcels bear the following legal descriptions, respectively: a) PID [...] b) PID [...] c) PID [...] d) PID [...] e) PID [...] f) PID [...] g) PID [...] h) PID [...] ... Parcel PID [...] [XYZ] is [#] acres and contains the couple's residence, which was built in 1979. 4. ...

STATEMENT OF FACTS You have provided the following documents: * […] (the Dealer Agreement), dated [mm/dd/yyyy], outlining […] (the Dealer’s) services provided to […]([…][Company X]). * a Credit Agreement between the Dealer, a Buyer, and […] (the Lender) upon assignment. * the Lender’s […] chart effective [mm/dd/yyyy], and * a Deal Management chart. ... A dealer reserve is based on the loan amount, and is expressed either as a percentage of the loan amount on fixed rate loans over $[…] or a dollar value ranging from $[…] to $[…] on variable rate loans and fixed rate loans of $[…] to $[…]. As an “extra bonus” the chart also indicates an additional $[…] Dealer Reserve is available for […] applications. ...

XXXXX a Web site; XXXXX. •   XXXXX offers memberships for a fee XXXXX. Individuals who purchase memberships XXXXX and the right to enter the Web site XXXXX. •   XXXXX. •   XXXXX employs individuals, who are resident in Canada, to search the Internet XXXXX. •   XXXXX. •   XXXXX. •   XXXXX. •   XXXXX. •   XXXXX. •   The server is located in Canada XXXXX. •   XXXXX makes this supply to both residents and non-residents of Canada. ... Leyton Border Issues Unit General Operations and Border Issues Division Excise and GST/HST Rulings Directorate 2006/03/17 — RITS 60371 — Application of GST/HST on Vehicle "Trade-ins" ...

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. ...