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On July 1, 2010, a number of changes to the tax regime in Ontario took place that impacted RetailerCo and […][certain suppliers and] that effectively resulted in the revaluation of inventory held by RetailerCo and increased the revenue to […][suppliers] (without increasing prices) […] [Those changes include:] * The elimination of the […][Ontario Provincial Sales Tax]; and * The transition […][to the GST/HST] in Ontario. 3. […][Information about ACo, a supplier]. 4. […][ACo sells product to RetailCo]. 5. […][RetailerCo charges ACo for certain product marketing activities] 6. […]. 7. […][information about detailed net account statements]. 8. […]. 9. […], the various changes to the tax regime in Ontario resulted in [ACo] effectively receiving increased revenue from each product unit without implementing a price change. 10. You provided […] a numerical example […][of a detailed calculation of the inventory revaluation] at the time of the transition: […] 11. On [mm/dd/yyyy], [ACo] received an adjustment payment of $[…] from RetailerCo, which was the result of calculations made in respect of the HST included in the value of inventory […][supplied to RetailCo prior to] July 1, 2010. 12. […]. 13. […]. ...

(Footnote 1) 4. […] (Footnote 2) 5. The Centre’s mission is […] (Footnote 3). […]. 6. Health care services at the Centre are provided by […] 7. […] 8. […], the Centre provides the following services and programs (Footnote 4): 9. […] 10. ... The Centre currently claims PSB rebates of 50% of the GST and federal part of the HST, and 82% of the provincial part of the HST, as a “charity”. 15. […]. […] (Footnote 5) 16. [...]. ...

[The Corporation] was continued under […] of […][Provincial Act Z] (Footnote 1). 2. ... The categories are: Category 1 – A body created by a government in legislation; Category 2 – A body incorporated by a government; and Category 3 – A body that meets the following criteria – (a) a government has taken action relating to the body; (b) the body is set up to undertake a public service function that government usually undertakes; and (c) the government retains the overall authority for the regulatory program, and the body remains accountable to the government. ... Yours truly, Desneiges Arbour Charities and Non-profit Organizations Unit Public Service Bodies and Governments Division Excise and GST/HST Rulings Directorate FOOTNOTES 1 […]. 2 […] 3 […] ...

Kinesiology services are not covered under the Medical Services Plan (MSP) of British Columbia. 7. […] 8. […][Information about GST/HST registration]. 9. […]. ... RULING GIVEN Based on the facts set out above, we rule that: 1) The supply of a kinesiology service […] is taxable; 2) GST/HST is payable […]; 3) Supplies of kinesiology services […] are taxable. ... For […] GST/HST registrants (a GST/HST registrant is a person who is registered for the GST/HST or who is required to be registered), GST/HST applies to the value of the consideration for such supplies made in Canada. […] […]. ...

21 August 1998 GST/HST Ruling HQR0001131- Application of the GST/HST to Transportation Services Unedited CRA Tags ETA Sch V, Part VI, 24 XXXXX GST/HST Rulings and Interpretations   Directorate Place Vanier, Tower C, 10th Floor 25 McArthur Avenue Vanier, ON K1A 0L5Case: HQR0001131 XXXXX Business Number: XXXXX NCS: 11890-1, 11895-6 Attention: XXXXX August 21, 1998 Subject: GST/HST APPLICATION RULING XXXXX Dear XXXXX Thank you for your letter of March 24, 1998, with attachments, concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the transactions described below. ... Our understanding of the facts is as follows: Statement of Facts •   XXXXX was incorporated under the XXXXX, 1995. •   The shares of XXXXX are owned exclusively by the XXXXX[.] •   The current XXXXX[.] •   XXXXX[.] •   XXXXX has not been designated to be a "municipal transit service" under section 24 of Part VI of Schedule V. •   XXXXX is not a Crown Corporation and is not considered to be a government entity that is exempt of paying the GST under the Reciprocal Taxation Agreement. •   XXXXX responsibilities are set out XXXXX[.] •   The cost of the operating expenses of XXXXX is considerably higher than the value of the fares collected. There is a formula for funding the deficit in the XXXXX[.] •   The fares which are collected by XXXXX and reported in XXXXX financial statements, are passed on to XXXXX to permit the latter to account for the subsidies that it must provide to XXXXX to fund their deficit. •   XXXXX has its own corporate offices and employees, and uses its own logo and colour scheme on the vehicles. •   XXXXX has a Services Agreement with XXXXX whereby the latter provides services such as snow and ice removal, cleaning and repair, janitorial, electrical and painting, security, fare inspection, administrative and financial, risk management and fire prevention. ...

In [yyyy], you purchased a new unit manufactured by [...], a [...] park model trailer. The unit measures [...]' by [...]'. 2. The [...] park model trailer is a manufactured unit that was delivered to the site by a professional trailer service, using specialized equipment for its transport. 3. ... You built a three-season sitting room/Florida room addition measuring [...]' x [...]' to the original unit. ...

Statement of Facts Our understanding of the facts, the transactions, and the purpose of the transactions, based upon XXXXX letter and discussions with both XXXXX and XXXXX, is as follows: •   XXXXX, XXXXX and the XXXXX are licencees under the EA and operate bonded warehouses; •   XXXXX and XXXXX supply their products "in-bond" to the XXXXX; •   It has always been the practice of XXXXX and XXXXX to invoice Canadian Liquor Control Boards and to include GST based on the duty and excise tax paid value of the goods shipped; •   XXXXX; •   XXXXX; •   Consequently, as at July 3, 2001, this had resulted in excess cash outflow of approximately XXXXX to XXXXX and XXXXX. Transaction(s) •   XXXXX and XXXXX supply their products "in-bond" to the XXXXX; •   XXXXX and XXXXX remit to the CCRA, GST based on duty-paid value of goods sold to the XXXXX; •   XXXXX. ... Explanation •   Pursuant to the Excise Act (EA), spirits are subject to excise duty, ascertained and levied at production; however, the duty is subject to deferral mechanisms such as transfers "in-bond", which generally defer the time when duty becomes payable until the spirits are "entered for consumption"; •   Pursuant to sub. 165(1) of the ETA, taxable "supplies" of goods are subject to GST/HST calculated upon the value of the "consideration" for the supply; •   Pursuant to s. 154, ETA, "consideration" includes any amount of excise duty that is "payable"; •   Canadian distillers, manufacturers and liquor boards are licencees under the EA and operate bonded warehouses; •   Canadian distillers generally supply their products "in-bond" to manufacturers and provincial liquor boards, deferring the payment of excise duty until the spirits are "entered for consumption" (usually, when they leave the final bonded warehouse in the supply chain); •   When spirits are "entered for consumption," excise duty becomes payable; •   Where spirits are supplied in circumstances where the duty is not yet payable (e.g. while in bond), the GST/HST payable in respect of the supply is calculated on the value of the consideration for the supply, excluding excise duty (i.e. the amount invoiced); •   Where spirits are supplied at a point in time after the excise duty becomes payable, the GST/HST payable is calculated on the value of the consideration for the supply that includes the duty. ...

STATEMENT OF FACTS We understand the facts to be as follows: 1. […] (the Company) is a GST/HST registrant […]. 2. ... The back label of Product 1, in reference to the product, states […][description of product and health claims][…]- […] 100% medium chain triglycerides, […] 5. […]. 6. ... Furthermore, suggested use indicates to build from [#] teaspoon up to [#] tablespoon [#] times a day. ...

[The Operator] is governed by a [...] in conjunction with [...]. You have indicated that it is a division (BN [...]) of [...] ... Tab 0807-01 of the Manual defines the domains of care as:- Activities of Daily Living (ADL): • eating; • toileting; • transferring; and • dressing.- Behaviours of Daily Living (BDL): • potential for injury to self or others; and • ineffective coping.- Continuing Care Level (CCL): • urinary continence; and • bowel continence. 14. ... B [...] C [...] D [...] E [...] F [...] G [...] Total [...] 16. [The Operator] provides a holistic approach to health care. ...